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All data available on the components of the submission substance show a very low aquatic toxicity. Phosphate and humic acids are natural constituents of soils. Phosphate has been shown to be beneficial for soil organisms, as it reduces bioavailability and toxicity of heavy metals to soil organisms. Toxicity to earthworms was observed at very high soil concentrations only (Ownby et al., 2005). In addition, the submission substance is well soluble in water and its chemical properties do not indicate bioaccumulation and/or adsorption to soil. Therefore, further data on terrestrial toxicity are not considered necessary.