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Long-term toxicity to fish

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No studies on the chronic toxicity to fish are available for the members of the PFAE fumarates category. Nevertheless, the acute aquatic toxicity tests of these esters clearly showed no effects occurring in the range of water solubility in fish, Daphnia nor algae. Furthermore, only negligible releases into surface waters from sewage treatment plants are expected to take place due to: a) the rapid biodegradability and b) the high adsorption properties and low water solubility’s of these substances, resulting in an effective removal in sewage treatment plants. Therefore chronic exposure of aquatic organisms is unlikely. In addition, available data indicate that all members of the PFAE fumarates are not bioaccumulative. In addition, the ECHA Guidance on information requirements and chemical safety assessment, Chapter R.7b (ECHA, 2012b) states that “chronic fish toxicity testing is generally only necessary, when the P and B criteria are fulfilled” and this is clearly not the case. Hence due to animal welfare reasons and to avoid unnecessary vertebrate tests, no further long-term test with fish is required for any member of the PFAE fumarates category.