Turkey makes a fresh start to 2018 with a new chemicals management plan in place for the industry.
Companies putting chemicals on the Turkish market must comply with the Turkish chemicals regulations in line with the European Union (EU). Turkish CLP, By-Law on Classification, Labelling and Packaging of Hazardous Substances abbreviated as SEA, was already implemented in the country in 2013 and transition periods are over. The year 2018 is engraved on our minds with the last registration deadline for EU REACH Regulation. Meanwhile, 2018 is also the beginning of a new regulatory experience, full of preparations and decisions to make for companies to comply with Turkish REACH, abbreviated as KKDIK, not only for the Turkish industry, but also for those who import chemicals to Turkey. By the end of 2023, all substances on the Turkish market have to be registered.
After several draft regulations, consultations with stakeholders and hard work put into the EU REACH implementation, KKDIK was published on 23rd of June 2017. The regulation and the guidance documents released by the national authority during the course of the second semester are basically translations of the EU REACH Regulation itself and the European Chemicals Agency (ECHA) guidance documents. This new regulation officially entered into force on 23rd of December 2017 with the purpose of aligning Turkish chemicals regulatory management to that of the EU. Although there are some changes to embody the correlated Turkish laws into the regulation and to adapt the regulation to the current regulatory conditions in Turkey, the data requirements to register a substance according to KKDIK remains the same as in the EU. However, the registration dossier must be in Turkish prepared via the online system KKS (Kimyasal Kayıt Sistemi) , implemented by the Ministry of Environment and Urbanization (MoEU) as a hybrid of REACH-IT and an older version of IUCLID. KKS online system is being used for CL Notifications by the industry according to the SEA regulation in Turkey since 2015. MOEU is planning to upgrade KKS system content to the latest version of IUCLID before registrations start.
Meanwhile, Turkish By-Law on Inventory and Control of Chemicals (CICR) which enabled MoEU to prepare a general inventory of chemicals put on the Turkish market was repealed the day KKDIK was published and some provisions of the KKDIK regulation came into force on the 23rd December 2017, just 6 months after the date it was published. An outstanding aspect of KKDIK under discussion is the obligation for Chemical Safety Reports (CSR) to be prepared by experts who must go through a tough training course of 64 hours and get certified through an examination. Turkish CSR issue has led to quite a few discussions in the regulatory environment for various reasons.
The Only Representative (OR) role and definition (KKDIK – Article 9) in the regulation is identical with the EU REACH Regulation (Article 8). Non-Turkish companies putting chemicals on the Turkish market must appoint an OR to comply with the obligation to (pre)-register. RGS recommends companies to take a meticulous decision when appointing their OR since there are several local environmental consultancy companies with no REACH experience at all, planning to give undervalued local OR services. Despite the fact that the deadline for (pre)-registration is the end of 2020, companies with intentions to register substances must join the pre-SIEFs to get ready for registration and be involved in the establishment of consortia. OR plays a key role as incorrect interpretation of the Turkish regulation and misleading information as well as wrong advice on actions to take at the Substance Information Exchange Forums (SIEFs) may lead to loss of money and waste of time.
RGS celebrates 10 years of EU Chemicals Regulatory Compliance servicing with hundreds of clients all over the world. Do not hesitate to contact RGS, if you need compliance with Turkish Chemicals Laws or more details on our services and the status of your substances.
Dr. Yaprak Yuzak Kucukvar
RGS Turkey Branch Manager