Registration phase of Turkish REACH Regulation, KKDIK is continuing as planned with gradual increase in SIEF communications. Meanwhile, updates and upgrades of the MoEU online Chemicals Registration System, KKS are under progress in preparation for registration submissions.
KKDIK Substance registration dossiers will be prepared and submitted online via KKS. Manufacturers and importers in Turkey must fill in their own company information under KKS Substance Management Module Section 1.7 “Suppliers”. Similarly, a non-Turkish manufacturer who appointed an Only Representative must provide information on the suppliers (Turkish importers) of the substance under Section 1.7 in order to fullfill its obligations for KKDIK. This information must be provided to the Only Representative appointed for that substance by the non-Turkish manufacturer and defined in Suppliers List under KKS by the OR. The OR is legally responsible to keep track of Downstream Users (DU) information and volumes associated with each DU according to the KKDIK regulation.
Manufacturers, importers or article manufacturers who perform PPORD notifications also need to provide their customers (in Turkey) to the MoEU via Section 1.7. For the suppliers to be added to the Suppliers list (Section 1.7), that particular company in Turkey must be registered under the EÇBS short for Entegre Çevre Bilgi Sistemi (Integrated Environmental Information System). The required company information is directly transferred from EÇBS.
EU REACH Regulation does not distinguish between direct and indirect imports according to the ECHA Guidance on Registration. That principle is also applicable under KKDIK as MoEU officially published the translation of ECHA guidance documents to Turkish language with minor adaptations. The OR is legally responsible for tracking the volumes covered and DU information per substance and plays an important role to gather this information for Section 1.7 in the event of complex supply chains. The non-Turkish manufacturer may be willing to cover the indirect exports to Turkey but will not be able to access the Supplier information which is defined as DU information according to REACH terminology. Unless this information is provided with the dossier, that DU and associated volume will not be considered as covered under the registration by the MoEU. Such information is confidential business information for the actors down the supply chain when indirect export is the case. Therefore, collection and management of this data requires professional OR and trustee services and secure IT systems to archive. This emphasizes the importance of trustworthy relations of the OR with the several actors in the supply chain of a substance OR is representing.
RGS Group based in Brussels, Belgium with offices in Istanbul, Turkey is representing global companies located in over 50 countries as a local Only representative through its Turkish presence. As a leading company, RGS also transfers 13 years of regulatory experience predominantly in EU REACH experience to its operations in Turkey. Do not hesitate to contact RGS, if you need more details on our services. We can assess your compliance status and build tailor-made solutions for your company.
Dr.Yaprak Yüzak Küçükvar
REACH Global Services Group
Director, Global Regulatory Affairs & Product Stewardship