Introduction to Turkish KKDIK Regulation 2017
Little Pro on 2017-07-04
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
| Obligations | Description |
|---|---|
| Registration |
|
| Safety data sheet |
|
| Authorization |
|
| Restriction |
|
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.
References
- Turkey publishes law modelled on REACH (CW News, July 2017)
- KKDIK regulation in official Gazette - in Turkish (June 2017)
- KKDIK regulation - English translation
- KKDIK regulation annex 17 - English translation
- KKDIK regulation annex 18 - English translation
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Tags: Topics - Turkey, REACH-like Regulation and Registration