Companies are going through a critical period for compliance with EU REACH as the deadline of 1 June 2018 is getting closer and closer. Lead Registrants are rushing to submit registration dossiers on time, and many co-registrants are under pressure as many have already signed SIEF/Consortia Agreements and purchased Letter of Access (LOA) for their substances. Failure to register on time or a rejection from ECHA may cost Lead Registrants and co-registrants incommensurable business loss. Moreover, as Lead Registrants are carrying liabilities towards co-registrants, legal actions may be launched to solve conflicts.
Companies planning to submit their registration dossiers to ECHA after March 2018 may need to wait up to 3 months for a registration number assigned to their substance by ECHA. This is a consequence due to high number of submissions expected during the last 2 months before the deadline, and ECHA’s delicate process for checking the full completeness of the submissions. There are several outcomes of these obstacles in the supply chain for downstream users and EU importers. Despite two successful previous registration deadlines and 10 years of REACH&IT experience of ECHA regarding, this last registration deadline and the amount of dossiers predicted to be submitted at the last minute worries the industry.
Meanwhile, just like several other “REACH-like” countries, Turkey is also implementing its national chemicals regulation, KKDIK, which is almost a copy paste of REACH. The fact that single registration deadline applies to all chemicals put on the Turkish market regardless of the hazard classification and tonnage band is the major difference of KKDIK compared to EU REACH Regulation.
The registration dossier must be in Turkish submitted via the KKS (Chemicals Registration System), an online system implemented by the Ministry of Environment and Urbanization (MoEU) as a hybrid of REACH-IT and an older version of IUCLID. KKS 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 starts. However, considering the overall EU REACH experience, one can worry how MoEU IT system will cope with high number of online submissions taking into account several companies prefer last minute compliance actions in Turkey. The good news is that KKDIK came into effect on 23 December 2017 and companies have already started to join the pre-SIEFs of their substances which means initial preparations for compliance has already started.
This should bring to mind that if companies placing chemicals on the Turkish market are planning to work with a local Only Representative to accomplish this tricky piece of compliance work, then the decision has to be taken very carefully. It is highly recommendable for the manufacturers to make a thorough assessment of the capacity, experience and references of the OR they consider to appoint. It is important to keep in mind that KKDIK obligations resulting with Chemical Safety Reports (CSR) to be prepared and signed by a certified expert triggers the necessity that your local OR has a proven experience and a qualified team of experts who can help your company to comply without any hassle.
RGS acts as an OR and Responsible Person (RP) for hundreds of non-EU manufacturers regarding EU REACH and EU Cosmetics Regulations. In addition, RGS-Turkey branch offices are representing numerous manufacturers from all over the world enabling these companies to comply with Turkish chemicals regulations which are in force and gradually brought in line with the EU Regulations for the last 7 years. RGS celebrates 10 years of success and experience with its experts of high qualification. Do not hesitate to contact RGS, if you need compliance with Turkish Chemicals Regulations or more details on our services and the status of your substances.
Dr. Yaprak Yuzak Kucukvar
RGS Turkey Branch Manager