Turkey KKDIK, SEA & GBF Regulations
Through our office in Istanbul, REACHLaw is helping considerable number of Turkish companies and companies located outside Turkey to comply with KKDIK, SEA and GBF regulatory requirements. Since the year 2011, we have provided to the companies Only Representative services but have also helped Turkish companies as their service provider!
KKDIK is now in force!
The “KKDIK Regulation” of June 23rd, 2017 (Regulation No. 30105) sets up a system for the Registration, Evaluation, Authorisation and Restriction of Chemicals in the Turkish market. Therefore, from 23rd of December 2017 manufacturing and importing companies of chemical substances as such or as part of mixtures or articles, in quantities equal to or above 1 tonne per year, can start pre-registering their substances to the MoEU in Turkey.
Under KKDIK there are not staggered deadlines above 1 tonne per year and substances are required to be pre-registered by the 31st of December 2020 and registered by the 31st of December 2023. Please note that only trained and qualified experts can sign off registrations to be submitted via a Turkish entity, therefore companies located outside Turkey can appoint REACHLaw as their Only Representative for this purpose.
Furthermore, the Turkish regulation on Preparation and Issue of Safety Data Sheets for Dangerous Substances and Mixtures, “GBF Regulation”, of December 13th, 2014 (Regulation No. 29204) requires companies to prepare compliant SDSs in Turkish language by a certified expert (in Turkey) and submit them to the MoEU. The safety information must be notified in Turkish language to the MoEU.
Likewise, the Regulation on Classification, Labelling and Packaging, “SEA Regulation”, of December 11th, 2013 (Regulation No. 28848) requires classification and labelling notifications for hazardous substances placed on the Turkish market regardless of their tonnage band. To comply with the SEA regulation, substance specific environmental, health and safety information of the substance must be submitted to the MoEU in Turkish language via a Turkish entity.
To manufacture and/or place chemicals on the Turkish market, companies must comply with these Regulations, either through their companies located in Turkey or through established Only Representatives also located in Turkey.
Via our Istanbul office, REACHLaw is happy to provide you with a full set of regulatory services to ensure compliance in your business with Turkey Regulations: KKDIK, SEA and GBF as your Only Representative or as your service provider!
REACHLaw Office in Istanbul:
Address: Orjin Maslak İş Merkezi, Eski Büyükdere Cad. 34485 34. Istanbul. Turkey.
Phone: +90 212 403 2537
Our Support Includes
Via our Istanbul office, REACHLaw is happy to provide you with resources and expertise necessary to perform the Only Representative obligations under KKDIK and SEA regulations, including appointment letter. The service is substance specific and is required for maintaining relevant data and compliances.
REACHLaw is a significant Only Representative service provider in both the European Union and Turkey!
On the 23th of June 2017, the Turkish Ministry of Environment and Urbanization ( MoEU) has issued the promised Turkey KKDIK regulation that came in force on 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 tonne per year.
KKDIK replaces following regulations:
- The Inventory and Control of Chemical Regulation (KEK). Effective date: 23 June, 2017
- Regulation on Restrictions for the Manufacture, Marketing and Use of certain Dangerous Substances and preparation. Effective date: 23 December, 2017
- Regulation on Safety Data Sheets for Hazardous Substances and Mixtures ( GBF). Effective date: 31 December, 2023
Main Obligations under KKDIK
|Pre-registration||31 December, 2020|
|Registration||31 December, 2023|
|Authorisation||Date/Substance in Annex XIV|
|Restriction||Dates stated 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 tonne per year, are required to be pre-registered by 31 December, 2020 and registered by 31 December, 2023.
All registrants ( Manufacturers, Importers, Formulators, Only Representatives) will need to pre-register their substances identity and role in the supply chain through the Ministry’s Chemical Registration System Portal ( KKS). Companies that have already done classification-inventory notification (SEA) will be able to transfer this information to the pre-registration portal of the MoEU.
The registration process is carried out by submitting a substance registration dossier to MoEU and will begin on the 1st January, 2021, right after the pre-registration deadline, and will end on the 31st of December, 2023. In addition, KKDIK requires that only trained and qualified experts can sign off registrations to be submitted to the MoEU. The safety information must be submitted in Turkish language to the Ministry.
Under KKDIK there are not specific deadlines for tonnage bands above 1 tonne per year and like in EU REACH, companies located outside Turkey can appoint an Only Representative in Turkey for Pre-registration and registration purposes.
REACHLaw would be happy to provide you as your OR or as your service provider with all-in-one service for properly compiling and submitting the pre-registration and registration dossiers to the MoEU.
All hazardous substances, including hazardous polymers, placed on the Turkish market must be SEA notified to the Ministry of Environment and Urbanization (MoEU) regardless of the annual tonnage. Furthermore, all non-hazardous substances subject to KKDIK registration, meaning substances at 1 t/a or more unless specifically exempt from registration, must also be SEA notified.
If your company is located outside Turkey we are happy to help you SEA notify substances as your Legal Representative through our Istanbul office or as your service provider. As a Legal Representative, we SEA notify substances on behalf of your importers so that they do not have to do it themselves.
Our Support includes:
- C&L Notification
- Legal Representative service to non-Turkish companies
- Labelling services
The Turkish SDS Regulation: GBF, came into force on 15 December, 2014. It requires companies to align Turkish SDSs according to the new format stated in the GBF regulation. Therefore, both mixtures and substances SDSs must be prepared by a certified expert in Turkey and authored in Turkish language. In addition, importers in Turkey and manufacturers in Turkey must submit a copy of the SDSs to the MoEU via KKS tool.
Through our certified experts and Istanbul office REACHLaw is happy to help you with the preparation and certification of your Turkish SDSs.