Letter to the editor regarding Collard et al. (2023): “Persistence and mobility (defined as organic-carbon partitioning) do not correlate to the detection of substances found in surface and groundwater: Criticism of the regulatory concept of persistent a

“We wish to make readers of the recently published article by Collard et al. (2023) aware that it is based on several false claims in relation to the regulatory concept of introducing new hazard classes for persistent, mobile and toxic (PMT) substances and very persistent and very mobile (vPvM) substances. Specifically, these false claims misrepresent the underlying scientific justification and regulatory purpose of the PMT/vPvM criteria. The PMT/vPvM criteria were adopted in the European Union´s CLP Regulation on April 20th, 2023, as part of the introduction of the new hazard classes PMT and vPvM. We feel it necessary to highlight these false claims, in view of the potential impacts these claims could have on the ongoing discussions regarding the adaptation of the new hazard classes PMT and vPvM in the Globally Harmonized System of Classification and Labelling of Chemicals of the United Nations (UN GHS).”

(Citation: H.P.H. Arp, R. Wolf, S.E. Hale, et al. – Letter to the editor regarding Collard et al. (2023): “Persistence and mobility (defined as organic-carbon partitioning) do not correlate to the detection of substances found in surface and groundwater: Criticism of the regulatory concept of persistent and mobile substances” – Science of the Total Environment (2023) DOI: 10.1016/j.scitotenv.2023.165927 – In Press, Journal Pre-proof)

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