SERVICES

Turkish REACH - KKDIK

Turkish REACH regulation, abbreviated as KKDIK which stands for Registration (Kayit), Evaluation (Degerlendirme), Authorisation (Izin) and Restriction (Kisitlama) of Chemicals (Kimyasallar) in Turkish is published as of June, 23, 2017 by the Ministry of Environment and Urbanisation (MoEU) which is the responsible authority for its implementation and enforcement. One should bear in mind that, as underlined in art. 65 of the new Regulation, KKDIK is a logical result of Turkey’s regulatory approximation process within the ongoing accession negotiations and the EU-Turkey Customs Union entered into force in 1995. Therefore, after the EU REACH implementation in 2008, a draft KKDIK Regulation was already published by MoEU in 2013, which was subject to several amendments since then. The Turkish Competent Authority, MoEU, organised several workshops and meetings with the stakeholders a few months ago and reflected some changes to the draft regulation after the last round of consultation with the chemical industry and stakeholders.

Although KKDIK is almost a copy-paste of the EU REACH Regulation, there are unavoidably slight differences as a result of the timing of Turkey introducing KKDIK. For instance, Turkish CLP Regulation known as SEA was put into force before KKDIK Regulation, which is differing from the situation in the EU. KKDIK is also foreseeing a pre-registration process and a Substance Information Exchange Forum called MBDF, very similar to SIEF formation. However, the striking difference between EU REACH and KKDIK is that pre-registration tonnage band will not trigger the deadline for registration. Registration period or the deadline for registration will be the same for all substances pre-registered and a 3 years time frame is envisaged for the registration period. One of the important additional requirements of KKDIK when compared with EU REACH is that Chemical Safety Report should be prepared and signed by a local Certified Risk Assessor. Similar requirements are in place under the SDS Regulation of Turkey. SDSs have to be prepared in Turkish and signed by a certified Turkish expert. More details about the requirements for the qualified persons to issue the Chemical Safety Report, certification criteria and Certifying Bodies will be available in Annex XIIX of KKDIK.

There is plenty of regulatory compliance burden involved for local and international companies that are putting chemicals on the Turkish market either as an importer, distributor or manufacturer. The scope of Article 8 of the EU REACH remains identical in Article 9 of the Turkish KKDIK regulation, and the responsibilities of an Only Representative (OR) is similar in KKDIK. Manufacturers located outside of Turkey, putting products on the national market must appoint an OR to comply with the regulatory obligations. It is inevitable for companies established outside of Turkey to appoint an Only Representative, or even those manufacturing locally in Turkey to appoint a Trustee, that is specialized and technically skilled at consulting and supplying trustee services to comply with the regulation. In this context, when technical, legal and legislative obligations are taken into consideration, the decision on this long-term cooperation based on mutual trust is very critical.

RGS continues to convey its rich experience, gained through EU REACH since 2008, and within the preliminary Turkish regulations like CICR / Turkish CLP (SEA) by adding the Only Representative services in the framework of the KKDIK regulation.

Do not hesitate to contact us at info@reach-gs.eu for more information regarding KKDIK and other Turkish Chemical Regulations and for determining your obligations.

 

Tags:
kkdik
turkish reach regulation
turkish reach
Turkish chemical regulation
kkdik consultant
kkdik Turkey
kkdik chemical safety report
kkdik directive
turkey chemical regulation
kkdik mbdf
kkdik registration
turkey reach
kkdik regulation
turkish reach
reach regulation in turkey
turkey safety data sheet
turkey sds
turkish sds

TOP

© 2017 REACH Global Services S.A. All rights reserved !
» Legal Notice & Privacy
Dil