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Metal carboxylates are salts consisting of metal cation and carboxylic acid anion. Based on the solubility of zinc didocosanoate in water, a complete dissociation upon dissolution (even if low based on water solubility limit of 1.1 microg/L) resulting in zinc and docosanoate ions may be assumed under environmental conditions. The respective dissociation is in principle reversible and the ratio of the salt /dissociated ions is dependent on the metal-ligand dissociation constant of the salt, the composition of the solution and its pH. However, under environmental conditions, a reunion of the dissociated ions is highly unlikely and it may reasonable be assumed that the respective behaviour of the dissociated zinc cations and docosanoate anions in the environment determine the fate of zinc didocosanoate upon dissolution with regard to (bio)degradation, bioaccumulation, partitioning resulting in a different relative distribution in environmental compartments (water, air, sediment and soil) and subsequently the (eco)toxicological potential. A metal-ligand complexation constant of zinc didocosanoate could not be identified. Data for zinc appear to be generally limited. However, zinc ions tend to form complexes with ionic character as a result of their low electronegativity. Further, the ionic bonding of zinc is typically described as resulting from electrostatic attractive forces between opposite charges, which increase with decreasing separation distance between ions. Based on an analysis by Carbonaro et al. (2007) of monodentate binding of zinc to negatively-charged oxygen donor atoms, including carboxylic functional groups, monodentate ligands such as docosanoate anions are not expected to bind strongly with zinc. Accordingly, protons will always out-compete zinc ions for complexation of monodentate ligands given equal activities of free zinc and hydrogen ions. The metal-ligand formation constants (log KML) of zinc with other carboxylic acids, i.e. acetic and benzoic acid, ranging from 0.56 to 1.59 (Bunting & Thong, 1969), further point to a low strength of the monodentate bond between carboxyl groups and zinc. The analysis by Carbonaro & Di Toro (2007) suggests that the following equation models monodentate binding to negatively-charged oxygen donor atoms of carboxylic functional groups: log KML = αO * log KHL + βO; where KML is the metal-ligand formation constant, KHL is the corresponding proton–ligand formation constant, and αO and βO are termed the Irving–Rossotti slope and intercept, respectively. Applying the equation and parameters derived by Carbonaro & Di Toro (2007) and the pKa of docosanoic acid of 4.95 results in: log KML = 0.301 * 4.95 + 0.015 log KML = 1.51 (estimated zinc- docosanoate formation constant). Thus, it may reasonably be assumed that based on the zinc didocosanoate formation constant the respective behaviour of the dissociated zinc cations and docosanoateanions in the environment determines the fate of zinc didocosanoate upon dissolution. In the assessment of environmental fate and toxicity of zinc didocosanoate, read-across to analogue substances and/or the assessment entities soluble zinc substances and docosanoic acid is applied since the ions of zinc didocosanoate determine the environmental fate and toxicity of zinc didocosanoate. Since zinc ions and docosanoate ions behave differently in the environment, a separate assessment of the environmental fate and toxicity of each assessment entity is performed. Please refer to the data as submitted for each individual assessment entity. For a documentation and justification of that approach, please refer to the separate document attached to section 13, namely Read Across Assessment Report for zinc behenate.

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