CLP comes to Turkey

Strict chemicals regulation is no longer exclusive to the European Union. Turkey is updating its chemicals regulations to get them more in line with its European trade partners to ease the passage of Turkish produced and formulated products to the EU single market. There is already a longstanding customs union and in the background the negotiations on Turkish accession to the EU continue. The negotiations have lasted already a decade since 2005 and are now said to be unlikely to be concluded before 2020 due to remaining political disagreements.

The recasting of EU CLP for Turkey and new safety data sheet regulation are causing a major compliance challenge for companies the Turkish market culminating this spring before the 1st June 2015 deadline when the new system is taking effect.  For an international company exporting their chemical products to Turkey the most important decisions need to be made right in the beginning. There are three main options to choose from. Firstly, regulatory compliance with these new regulations may be left to the Turkish importers but that requires that the importers are provided with detailed, potentially confidential business information necessary for compliance. Alternatively, the exporter may appoint their Turkish subsidiary as representative to comply with the regulations. Finally, the matter can be outsourced by naming as representative a professional service provider operating in Turkey. REACHLaw provides these services through our local subsidiary in Istanbul.   

According to the new regulation substance classification, labelling and packaging of substances need to be Turkey CLP-compliant by 1st June 2015. Corresponding updates need to be completed for mixtures by 1st June 2015. Classification notifications need to be completed to the Turkish Ministry of Environment and Urbanisation by the same deadlines. The Turkish classification notification includes essentially the same information as a EU CLP-notification: notifier identification information, place of manufacture, substance identification information, classification, limit values and M-factors and their justifications, hazard phraces and labelling information. Further information must to be provided when a substance cannot be classified as belonging to certain hazard classes and differentiations. The reason can be lack of information or that data is not sufficient for classification. 

The classification notification is made with the KKS-tool to the Ministry of Enviroment’s Environmental Information System (EIS) in the Turkish language. For safety data sheets there is a requirement to show both the old and new classification during the transition period 1st Jun 2015 – 1st June 2016. SDS updates can only be made by a Turkey trained and certificed SDS expert. The new SDS regulation was published on 13th December 2014 so the training of experts in the new systems needs to take place quickly.

Substance labels neds to be CLP-compliant by 1st June 2015. However, substances placed on the market before this deadline benefit from a grace period up to 1st January 2017. Similarly, mixtures on the shelf before the deadline of 1st June 2016 benefit from a grace period up to 1st June 2018.

The new obligations include a requirement to keep authorities and customers updated of the changes made. As a whole, compliance with Turkish chemicals regulations has already previously required a locally operating expert.

Further compliance work is expected to result from the newly drafted KKDIK-regulation with registration obligation on all chemicals on the Turkish market from end of the current year up to 31st December 2018. The KKDIK-regulation completes the long process to harmonise Turkish chemicals regulatory system with EU REACH and CLP.

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