On 23 June 2017, the Ministry of Environment and Urbanization(MoEU) in Turkey published its REACH-like KKDIK regulation. The KKDIK regulation will come into force on 23 Dec 2017. “KKDIK” are the first letters of REACH written in Turkish. Like EU REACH regulation, the KKDIK regulation requires companies to register all substances manufactured in Turkey or imported into Turkey with volume above 1t/y before a given deadline.
KKDIK will bring various Turkish chemicals legislation under one law. It will replace three existing laws:
- Regulation on the Inventory and Control of Chemicals;
- Regulation on the Preparation and Distribution of Safety Datasheets for Hazardous Materials and Products; and
- Regulation on the Restrictions Relating to the Production, Supply to the Market and Use of Certain Hazardous Materials, Products and Goods.
Scope of KKDIK Regulation (Turkey REACH)
KKDIK applies to all chemical substances on their own or in preparations as well as in articles. However, the regulation does not cover the following substances and mixtures.
- Radioactive substances and mixtures;
- Goods, mixtures or articles in transit and goods in free-zone for re-export;
- Non-isolated intermediates;
- Transport of dangerous substances and mixtures by various modes;
- Substances manufactured or imported for defense purpose;
- Medicinal products;
- Veterinary products;
- Medical devices;
- Cosmetic products;
- Food and feeds;
Note: Active substances and co-formulants which are only manufactured or imported for use in plant protection products are considered as registered under Turkey REACH. Active substances in approved biocidal products are also considered registered. However, plant protection products and biocidal products are not fully exempt under KKDIK regulation. For example, GHS safety data sheet and labelling are still required.
Industry’s Obligations under KKDIK
|Registration||Registrant: Manufacturer, importer and only representative;Target: all substances manufactured or imported >=1t/y, including substances intended to be released from articles.Pre-registration deadline: 31 Dec 2020Registration deadline: 31 Dec 20234 tonnage bands: 1-10t/y, 10-100t/y, 100-1000t/y, 1000t/y+;Data requirement and risk assessment report similar to EU REACH.Reduced registration requirements for substances used for product and process-oriented research and isolated intermediates.For polymers, monomers shall be registered if the volume of monomer exceeds 1t/y.Joint submission mandatory.|
|Safety data sheet||16-heading GHS safety data sheet;Must be in Turkish.|
|Authorization||Substances on annex 14 cannot be manufactured, imported or used unless an authorization has been granted;Candidate substances for inclusion in annex 14 similar to EU SVHC candidate list;Annex 14 similar to REACH Annex XIV Authorization List|
|Restriction||Must comply with restriction conditions set out in annex 17;Annex 17 similar to REACH Annex XVII Restricted Substances List.|
Differences between Turkey REACH and EU REACH
One of the key differences between REACH and KKDIK is that the KKDIK requires that only trained and qualified experts sign off registrations and notifications. Other than that, there are no major differences between Turkey KKDIK regulation and EU REACH. To comply with KKDIK regulation, companies mainly need to do the following 3 things.
- Pre-register/register applicable substances >=1t/y before given deadline. If your company is based outside of Turkey, you may need to appoint a local only representative.
- Ensure that your safety data sheets are compliant.
- Monitor the list of substances subject to authorization on annex 14 and the list of restricted substances on annex 17.