43However, as the Advocate General noted in point 79 of his Opinion, it is apparent from the very wording of the GHS, in particular Annex 9, entitled ‘Guidance on hazards to the aquatic environment’, that the indicated methodological approach for determining the classification of substances’ hazards to the aquatic environment is difficult due, inter alia, to the fact that ‘the term substances covers a wide range of chemicals, many of which pose difficult challenges to a classification system based on rigid criteria’. That document therefore highlights ‘a complex interpretational problem, even for experts’ presented by classification, in particular of so-called ‘complex or multi-component’ substances for which ‘biodegradation, bioaccumulation, partitioning behaviour and water solubility all present problems of interpretation, where each component of the mixture may behave differently’.
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