Turkey KKDIK - REACHLaw

KKDIK: The Turkish Regulation on Chemicals Registration, Evaluation, Auhtorisation and Restriction

On the 23th of June,2017, the Turkish Ministry of Environment and Urbanization (MoEU) has issued the promised Turkey KKDIK, regulation that will be enforced from 23 December, 2017.

The Turkey REACH like-law: KKDIK is closely harmonized with the EU REACH provisions and requires companies to pre-register and register substances (on their own, in mixtures or in articles) manufactured in Turkey or imported into Turkey with volumes equal to or above 1 tone per year.

KKDIK will replace following regulations:

Regulations	Effective date
– The Inventory and Control of Chemical Regulation (KEK)	23 June,2017
– Regulation on Restrictions for the Manufacture, Marketing and Use of certain Dangerous Substances and preparation	23 December, 2017
– Regulation on Safety Data Sheets for Hazardous Substances and Mixtures (GBF)	31 December,2023

Main obligations under KKDIK

Obligations	Deadlines
– Notification (ön-MBDF)	31 December, 2020
– Registration	31 December, 2026 31 December 2028 31 December 2030
– Authorisation	Date/substance in Annex XIV
– Restriction	Dates in Art.66

KKDIK: Pre-Registration and Registration Obligations

All substances (on their own, in mixtures or in articles) manufactured in Turkey or imported into Turkey with volumes equal to or above 1 tone per year, are required to get pre-registered by 31 December, 2020 and registered by 31 December, 2026, 2028, and 2030 based on tonnage annual band and substance hazards.

All registrants ( Manufacturers, Importers, Formulators, Only Representatives) will need to notify their substances indentity and role in the supply chain through the Ministry’s Chemical Registration System Portal. Companies that have already done Classification-Inventory Notification (SEA) will be able to transfer this information to the notification portal of the MoEU.

The registration process is carried out by submitting a substance registration dossier to the MoEU and will begin right after the pre-registration deadline (31 December,2020).

Under KKDIK there are specific deadlines as follows:

31.12.2026

Substances at ≥1 000 t/a
Substances classified as Aquatic Acute 1 and Aquatic Chronic 1 (H400, H410) at ≥100 t/a
CMR substances (Category 1A and 1B) at ≥1 t/a

31.12.2028

Substances at 100 – 1 000 t/a.

31.12.2030

Substances at 1 – 100 t/a

Companies located outside of Turkey can appoint an Only Representative (OR) in Turkey for pre-registration and registration purposes.

KKDIK: Obligations related to articles

a)Producers and importers are required to notify to the MoEU the substances listed on the Candidate list (same than in EU REACH) which are present in their articles if both following conditions are met:

The substance is present in their relevant articles above a concentration of 0.1% weight by weight
The substance is present in these relevant articles in quantities totalling over one tone per year.

b)Producers and importers are required to notify and register the substances intended to be released from their articles in quantities equal to or above 1 tone per year.

KKDIK: Application for Authorisation

The list of substances to be added to Annex XIV will be determined by the MoEU, in accordance with the REACH Regulation, and will be published on Ministry’s website.

Applications for authorisation can be submitted via the Ministry’s Chemical Registration System Portal and will be assessed by the MoEU. The Ministry will inform on its decision within 10 months.

KKDIK: Restriction

Companies must comply with Restriction conditions set out in Annex XVII ( Article 66 of KKDIK regulation).

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