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57(f) classifications may also be founded on GHS criteria such as respiratory or skin sensitisation which is, according to ECHA, of equivalent concern to CMRs.
Regarding these concerns and uncertainties, especially with respect to the precautionary principle, short-chain PFASs are of equivalent concern to PBT substances.
The definition of borderline chemicals and the directly implemented screening approach help to prioritize potential substances of very high concern or of equivalent concern out of a long list of chemicals.
Chemicals with (very) persistent, (very) bioaccumulative, and toxic properties (PBT and vPvB compounds), substances that are carcinogenic, mutagenic, and toxic to reproduction (CMR compounds), as well as chemicals of equivalent concern like endocrine disruptors (EDs), see Box 1, and sensitizers may be subject to authorization.
An indication of how the EU might deal with EDs, and thus BPA, is suggested by the EU Water Framework Directive (2000/60/EC), which looks at them as substances of equivalent concern to substances of relevance to the REACH Regulation.
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57 f) is suggesting as substances of an equivalent concern such as those having endocrine disrupting properties or those having persistent, bioaccumulative and toxic properties or very persistent and very bioaccumulative properties, which do not fulfil the criteria of Annex XIII.
If the substance shows LRTP instead, then it is regarded to be a borderline chemical and of equivalent high concern.
However, surprisingly, decisions in favour of PD only occur in 5% of all cases in Germany, even though both modalities are regarded as equivalent concerning mortality [ 2, 3].
Short-chain PFASs are increasingly used and are considered to have properties of very high concern according to Article 57(f) of the REACH Regulation: They are of equivalent level of concern to PBT or vPvB substances.
These considerations and the additional concerns, such as enrichment in the edible parts of plants and the accumulation in water resources (see "Overview of concerns of short-chain PFAAs"), show that short-chain PFASs are of equivalent level of concern compared to PBT/vPvB substances.
However, in our opinion short-chain PFASs are also of equivalent level of concern compared to PBT/vPvB substances and can be identified as SVHC for the following reasons: Article 1 of the REACH Regulation states that the provisions of the REACH Regulation are underpinned by the precautionary principle.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com