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Environmental fate & pathways

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According to the guidance given in Annex VII of REACH legislation and Chapter R.7B (Endpoint Specific Guidance) of the ECHA REACH Guidance Document (2008) the requirements for “Ready biodegradability” can be waived if the substance is inorganic.

For an inorganic substance for which the chemical assessment is based on the elemental concentration (i.e. pooling all inorganic speciation forms together), biotic degradation in the environment is an irrelevant process. Biotic processes may alter the speciation form of an element, but it will not eliminate the element from the environment by degradation or transformation processes. This elemental-based assessment (pooling all speciation forms together) can be considered as a worst-case assumption for the chemical assessment.