Chemicals management is taking its place on top of the priority list for manufacturers and exporters since there is a changing regulatory environment and new chemical legislations are being introduced all over the world; the most complicated one being the EU’s REACH regulation. As a benchmark, the REACH Regulation triggered Asia Pacific countries like China, Japan, South Korea, but also Turkey as a EU candidate country, to implement REACH.
Turkish Ministry of Environment and Urbanisation (MoEU) published two major By-Laws on Chemicals and a new regulation on Safety Data Sheets since 2008. Several EU Implementation Projects are on-going in Turkey and one of them completed in December 2013 resulting with the new Turkish REACH Regulation known as KKDIK that stands for Chemicals Registration, Evaluation, Authorisation and Restriction in Turkish.
Many companies completed their notifications for chemicals put into the Turkish market before March 2011 which was the deadline for By-Law on Inventory and Control of Chemicals commonly known as CICR. Importers and manufacturers of chemical substances, mixtures/formulations have the obligation to notify and update their notifications every 3 years according to the CICR unless they are exempt. The By-Law also allows companies exporting to Turkey to appoint a “Representative” to comply with the obligations rather than leaving the duty to the importers who do not have the information necessary to comply either because of confidentiality reasons or lack of technical background. This has led manufacturers out of Turkey to appoint local representatives who can fulfil manufacturers responsibilities and execute the job in Turkish language as requested. Consequently, a Turkish national inventory has been established since 2011.
Opposite to the EU approach, SEA is launced before Turkish REACH in Turkey. Turkish By-Law on Classification, Packaging and Labelling of dangerous substances and mixtures abbreviated as SEA was published in December 2013 with a notification deadline of June 2015 for the substances imported into the Turkish market before June 2015. However, the MoEU registration portal used for the SEA notification is open for companies who missed the deadline or have new substances to notify. Although CLP and SEA have a lot in common, there are also some differences. Foreign companies can submit notifications through their appointed representatives located in Turkey and assume that this is an exercise before the Turkish REACH (KKDIK) regulation as they will need to appoint an Only Representative to submit pre(registration)s through the same registration portal soon.
Finally, after several drafts and a delay as a result of the general elections on last November, KKDIK is to be published in the first quarter of 2016 by the MoEU. Therefore, all manufacturers have to be ready with a comprehensive inventory of substances, mixtures and articles they put into the Turkish market. It is mandatory for companies to go through a pre-registration process which already has been experienced as the first step before doing a SEA notification. This also leads companies to join a Substance Information Exchange Forum (SIEF) called ÖN MBDF (in Turkish) which will enable companies to communicate or co-operate on availability of required data and data sharing similar to EU REACH Regulation through SIEFs.
REACH Global Services S.A. (RGS) does not cooperate with a local partner, but instead is giving Turkish Compliance Services through their own Turkish Branch Office directly employing Turkish speaking qualified technical team having years of both EU REACH experience and Turkish Chemical Regulations. Please contact RGS if you are NOT Compliant with Turkish Chemicals Laws or need more details on our services.
Dr. Yaprak Yüzak KÜÇÜKVAR
Reach Global Services S.A.
Turkey Office Manager
www.reach-gs.eu
