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Toxicity to terrestrial plants

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The performance of a test for toxicity to terrestrial plants is scientifically unjustified. REACH Regulation (EC) No 1907/2006, Annex IX, Sect. 9.4, Col. 2, states as follows: “9.4: Effects on terrestrial organisms: These studies do not need to be conducted if direct and indirect exposure of the soil compartment is unlikely.” Direct and indirect exposure of the long-chain alkyl acrylate esters (C12-C14) to soil is highly unlikely. The alkyl acrylate esters (C12-C14) are readily biodegradable and therefore will not persist in soil. Furthermore, an indirect exposure to soil via sewage sludge transfer is unlikely. In addition, no direct releases to soil from point sources are known. Thus, toxicity to terrestrial plants was considered scientifically not justified.

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