Comments

Comm. NT: 4.
Upakkilesavimuttaudayabbayañāṇakathāvaṇṇanā

These modes, [that is, the three characteristics,] are not included in the aggregates because they are states without individual essence (asabhāva-dhammā);
and they are not separate from the aggregates because they are unapprehendable without the aggregates.
But they should be understood as appropriate conceptual differences (paññatti-visesā) that are reason for differentiation in the explaining of dangers in the five aggregates, and which are allowable by common usage in respect of the five aggregates.

пали	Uppādavayaññathattaṃ aniccalakkhaṇaṃ hutvā abhāvasaṅkhāto vā ākāravikāro.
Nyanamoli thera	Rise and fall and change are the characteristic of impermanence; or mode alteration, in other words, non-existence after having been [is the characteristic of impermanence].4