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PBT assessment

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PBT assessment: overall result

PBT status:
further information relevant for the PBT assessment is necessary
Justification:

Condensation Product of N-C12-C18-Alkylpropane-1,3-Diamine, N-(3-Aminopropyl)-N’-C12-C18-Alkylpropane-1,3-Diamine and Formic Acid has been determined to be not readily biodegradable. But no additional test is proposed to better characterize behaviour and biodegradation profile of this substance. Indeed,in the REACH Guidance this is indicated that for adsorptive substances, a lower degradation rate is generally expected in soil than in water-phase due to partly immobilization caused by sorption. Condensation Product of N-C12-C18-Alkylpropane-1,3-Diamine, N-(3-Aminopropyl)-N’-C12-C18-Alkylpropane-1,3-Diamine and Formic Acid is a cationic surfactant and thus sorbs easily to negatively charged surfaces. There is no principal difference between soil and sediments considering the sorption properties. Therefore, further testing in soil and sediment are not expected to deliver more information on the biodegradation of this substance. In adddition, these tests will be technically not feasible with this UVCB substance.

The logKow value of Condensation product of N-C12-C18-alkylpropane-1,3-diamine, N-(3 -aminopropyl) -N’-C12-C18-alkylpropane-1,3-diamine and formic acid has been measured (OECD 117): logKow > 4. Therefore the notifier proposes to carry out a bioconcentration test according to OECD 315 for addressing the question.

Based on the aquatic toxicity data set, it can be considered that Condensation product of N-C12-C18-alkylpropane-1,3-diamine, N-(3-aminopropyl) -N’-C12-C18-alkylpropane-1,3-diamine and formic acid fulfil the Toxic criterion.