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:
|– 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
|– Notification (ön-MBDF)||31 December, 2020|
|– Registration||31 December, 2023|
|– Authorisation||Date/substance in Annex XIV|
|– Restriction||Dates in Art.66|
Placing chemical substances on the Turkish market?
If you are located outside of Turkey, REACHLaw is happy to help you with your KKDIK notifications and registrations as your Only Representative (OR) via our Istanbul office. Or if you are located in Turkey, we can assist you as your service provider.
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, 2023.
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 notification deadline (31 December,2020) and will end on the 31st of December 2023.
Under KKDIK there are not specific deadlines for tonnage bands above 1 tone per year and like in EU REACH, companies located outside of Turkey can appoint an Only Representative (OR) in Turkey for notification 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.
Companies must comply with Restriction conditions set out in Annex XVII ( Article 66 of KKDIK regulation).
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