The Turkish ‘REACH’ Regulation, KKDIK ( "KKDIK" is the acronym for the translated title of the REACH: "Registration, evaluation, authorisation and restriction of chemicals" Regulation) was officially published on 23 June 2017 by the Ministry of Environment and Urbanization. KKDIK mirrors most aspects of the EU REACH Regulation, introducing registration duties for manufacturers and importers of substances placed on the market in quantities of 1 tonne or more per annum, data sharing mechanisms to avoid unnecessary vertebrate testing and obligations on downstream users. Registration applies to substances on their own, in mixtures and substances in articles where there is intended release.
Prior to KKDIK, Turkey’s chemical regulation imposed two notification requirements. The first was for substances placed on the Turkish market prior to March 2011, establishing a national inventory of chemical substances, under the Chemicals Inventory and Control Regulation. At the time, this regulation was referred to as Turkish REACH Regulation, but was a precursor to KKDIK. A second notification for hazardous substances was required to Turkey’s classification and labelling inventory, for compliance with Turkey’s regulation on Classification, labelling and Packaging of dangerous substances and preparations, known as SEA. The regulation was introduced to align with the EU CLP Regulation.
According to KKDIK, a pre-registration phase with a deadline of 31 December 2020 is expected, but a major difference is that the Turkish regulation implements one registration deadline for all substances. EU REACH facilitated for phased registration, based on hazard and volume over three timed deadlines. The KKDIK registration deadline has been set for 31 December 2023 and is set to commence at the end of pre-registration.
As with EU REACH, overseas entities can use an ‘Only Representative’ to undertake registration on their behalf. A chemical safety assessment and report are required for substances supplied to market in quantities of 10 tonnes or more per annum (per registrant), but chemical safety assessments can only be undertaken by qualified personnel, with a separate Annex detailing training and certification requirements (Annex 18).
The regulation also follows EU REACH in determining substances of very high concern for authorisation of use, which will be listed in Annex 14. Substances currently subject to restriction of use are identified in Annex 17 to the Regulation.
Turkey’s new regulation imposes further cost burden to the chemical industry, as a significant market for chemical producers. It is not yet clear whether EU REACH dossiers will be acceptable for KKDIK registration, which would in any case require translation to Turkish.
For more information on EU REACH and CLP Regulations, see EU Legislation
Page published July 2018
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