A blind spot in the assessment of POP/PBT/vPvB properties

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.