Pharmaceutical products are often synthesized by the use of reactive starting materials and intermediates. These can, either as impurities or through metabolic activation, bind to the DNA. Primary aromatic amines belong to the critical classes that are considered potentially mutagenic in the Ames test, so there is a great need for good prediction models for risk assessment. How primary aromatic amines exert their mutagenic potential can be rationalized by the widely accepted nitrenium ion hypothesis of covalent binding to the DNA of reactive electrophiles formed out of the aromatic amines. Since the reactive chemical species is different in chemical structure from the actual compound, it is difficult to achieve good predictions via classical descriptor or fingerprint-based machine learning. In this approach, we use a combination of different molecular and atomic descriptors that is able to describe different mechanistic aspects of the metabolic transformation leading from the primary aromatic amine to the reactive metabolite that binds to the DNA. Applied to a test set, the combination shows significantly better performance than models that only use one of these descriptors and complemented the general internal Ames mutagenicity prediction model at Bayer.