SIEF communications have increased over the past few weeks as more EU Consortia decided on their data sharing actions for Turkey’s upcoming KKDIK registration deadline (31st of December 2023). On October 11, The Ministry of Environment, Climate, and Urbanization (MoECC) convened in Ankara a short notice meeting, exclusively for the Lead Registrants and the Only Representative companies to hear about the problems they are experiencing during the registration processes and to exchange views about solution suggestions.

Insight Information Regarding the MoEUCC Meeting

During the meeting attended by about 100 participants, the striking news concerning the registrations was the announcement of the Ministry representatives concerning a circular note they will share soon with the industry. The circular sounds promising as it will include several topics that the registrants are keen to learn, such as amendments on data sharing, clarification on supplier information that is shared via the registration dossiers, enforcement, and monitoring, regulation on training and certification bodies and more.

Companies were still having hopes on a possible postponement of the 2023 registration deadline. Though the Ministry declared once again that they are not planning on changing this deadline. In fact, with the above mentioned circular there will be crucial changes impacting the lead registrants. It is now expected to have interim deadlines, such as March 2023, June 2023 for different tonnage bands.

The Ministry is trying to encourage the industry as much as possible, as there are only about 500 dossiers that have been submitted until now, in spite of the 7000 substances they have in their database for final registration. This resulted in another decision they announced at the meeting: since there are thousands of SIEFs without any Lead Registrant, the Ministry would designate the lead registrants amongst the potential co-registrants if they are unable to do so. Following this decisive explanation, the Ministry added that they are waiting for 5 days before starting to assess a dossier’s completeness check. Thus the Ministry will make sure that there is no objection from the SIEF members for that particular company to be the lead registrant and that no other co-registrant is challenging the accuracy of the submitted data by the LR.

There have been some discussions on how the co-registrants can act when they have a higher tonnage band than the lead registrant and what the lead registrant can do if they do not have all the relevant data for the dossier. In such scenarios a communication should be initiated within the SIEF to see if any other company do have the missing data.

Another critical new information was the confirmation by the Ministry that they will be looking for data content reflecting and referring to EU REACH dossiers. Where needed, companies will be able to discuss testing proposals with the MoEUCC as well.

Technical Bottlenecks Can Still Be Seen

Having a hybrid system of REACH-IT and IUCLID in Turkish language with a different IT infrastructure, Turkey is struggling with flaws especially in Chemical Safety Report (CSR) generation as the companies are unable to use the outcomes for dossier submittals. The Ministry is aware of these dysfunctionalities and it was confirmed that they are working at the highest level with the IT team to resolve these issues.

There were a lot of discussions on the section for collecting Downstream User information which may enable more audits in the future. On the other hand, there will be soon enforcement for restricted substances at customs authorities level.

We will hear more from the Ministry soon on their roadmap for having a comprehensive laboratory infrastructure in Turkey to analyze KKDIK data and keep costs at a minimum.

RGS Group based in Brussels, Belgium with a subsidiary in Istanbul, Turkey is representing global companies located in over 55 countries as a local Only representative through its Turkish subsidiary based in Istanbul. As a leading company, RGS also transfers 14 years of intensive regulatory experience in EU REACH to its operations in Turkey. Do not hesitate to contact RGS, if you need compliance with Turkish Chemicals Regulations or more details on our services.

REACH Global Services Group

Tugce Gizem Gurleroglu

Deputy Director