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This paper relates to the assessment of transformation products (i.e. metabolites degradation or reaction products) which are formed from plant protection products. It addresses a detail in Regulation (EC) No. 1107/2009 which is not in line with other substance regulations for REACH medicinal products and biocides. Our concern: Also transformation products can be hazardous substances. Meanwhile they are not yet covered within the POP/PBT/vPvB assessment and the approval criteria for active substances. Our proposal: At least transformation products occurring in a relevant amount should be included in the assessment and the approval criteria in the same way as active substances. |
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