Keeping you in the loop on Turkey KKDIK
We are very happy to share with you that our REACHLaw Turkey team has prepared and submitted successfully 7 KKDIK Lead Registration dossiers to the Turkish Ministry of Environment and Urbanization and Climate Change – MoEUCC. Our professional and certified team in Turkey continues with the preparation of many other lead and co-registration dossiers for the substances of our clients to ensure KKDIK compliance in their business after the KKDIK registration deadline: 31.12.2023.
We would like to share with you some updates on what’s going on with the KKDIK registration process and how companies can start or speed-up the registration work for their substances so that they are able to meet the 2023 KKDIK registration deadline.
- As of today more than 256 000 KKDIK pre-registrations have been submitted to the MoEUCC
- Although KKDIK lead registration work has started or has been completed for some of the pre-registered substances there is still a considerable number of substances without a nominated lead registrant. Keep in mind that joint submission is only possible when a lead registration dossier is available; otherwise, you won’t be able to co-register your substances
- The substance C&L Inventory has been published on the Turkish Chemical Data System (KIMVES) and companies are able to find C&L information for approximately more than 20 000 substances. Companies can search by substance name, EC or CAS numbers in the published inventory (https://kimves.cevre.gov.tr/KIMVES)
- Data-sharing process may be a complex and time-consuming exercise in most of the cases and therefore, companies placing substances on the Turkish market under the scope of KKDIK regulation must be aware of this and initiate an action plan so that they are able to safeguard their business in Turkey after 31.12.2023.
What are the actions that your company can take already now to meet successfully the 2023 KKDIK registration deadline?
- If you missed the KKDIK pre-registration deadline, don’t worry. You can still submit KKDIK pre-registration for your substances via the Turkish Chemical registration System- KKS so that you are able to join the SIEFs and initiate the registration process
- If your substance doesn’t have a nominated lead registrant yet, take a proactive action into the SIEFs by contacting the other co-registrants for the same substance; or you may consider to take the lead role to initiate the registration process for your substance(s)
- If you are a formulator relying on your supplier’s registration, make sure that the KKDIK registration done by your suppliers will cover the annual volumes you are placing on the Turkish market. If your suppliers are based outside Turkey, we strongly recommend you to seek a confirmation from your suppliers Turkish OR on the registration of the substances supplied to you that are contained in your formulations and that are placed on the Turkish market and are subject to KKDIK
- If you don’t have the expertise in-house to carry out with the KKDIK registration process, we advice you to look for a professional and experienced Only Representative in Turkey if you are a manufacturer or formulator located outside Turkey or for a service provider if you are located in Turkey. Keep in mind that the OR or the service provider you choose must have certified personnel to sign-off the KKDIK registration dossiers for your substances prior submission to the MoEUCC
Through our office in Turkey, we are able to provide you with a full set of services to complete the KKDIK registration process successfully and ensure compliance in your business. We can assist you as your Only Representative or as your service provider. Contact us at firstname.lastname@example.org for support.