Recently, the possibility of extending the deadline is at the top of everyone’s KKDIK agenda. Considering the challenges faced, the industry frequently expresses its concerns to the MoEUCC over different platforms and requests an extension of the initially announced official registration deadline of 31st December 2023. However, the MoEUCC did not make any official announcement in the official gazette, neither on non-official platforms.
For the past few months, Lead Registrations became a priority as being the very first step for successful joint submissions. Within this scope, the industry aims to complete lead registrations as soon as possible so that all other MBDF (SIEF) members can have enough time to prepare their joint submission dossiers.
MOEUCC OFFICIALS HELD AN INFORMATIVE SEMINAR REGARDING KKDIK AT KOCAELI CHAMBER OF COMMERCE ON 26 SEPTEMBER 2023
Postponing the Registration Deadline 31/12/2023 is not Planned in the Time Being
It was stated that the MoEUCC is currently evaluating feedbacks and requests from the industry for postponing the registration deadline, but that there is no such decision as a postponement for the time being and it cannot say otherwise at this stage. As a recommendation, it was stated that all registrants should consider the registration deadline as foreseen on the end of the year. However, the officials have also mentioned that they are evaluating requests and trying to find a solution to avoid likely bottlenecks after the registration deadline.
Dossier Evaluation after Registration Deadline
After the registration deadline, MoEUCC will select %5 of the registration dossiers and evaluate those comprehensively. MoEUCC will prioritise substances with high tonnage bands, having high exposure characteristics and being included in SVHC list.
Annex XIV & Annex XVII, Audits and inspections of Registrations
After the registration deadline, MoEUCC will publish and update Annex XIV (Authorisation List) & Annex XVII (Restriction List) during the first quarter of 2024. It was stated that Annex XIV could be similar to the EU REACH’s Annex.
Audits and inspections will be held by Auditors of Provincial Directorates of Environment and Custom Officials. KKS (Chemicals Registration System) database will be integrated into Custom Officials’ software.
TEDIOUS REGISTRATION PROCESS WITH NUMEROUS ISSUES LEADING TO CURRENT DELAYS
While there are less than 3 months to the deadline, the lead registration process is not moving as expected even for the substances which have appointed Lead Registrants. It is also worth mentioning that this long data entry process is only the tip of the iceberg. Apart from delays due to lead registration dossier preparations and submissions in KKS, the Data Licensing processes also takes significant time.
The registrants who are aware of the above-mentioned issues, initiate SIEF communications to speed up the process; unfortunately, very few SIEF members provide feedback in return. These non-responsiveness in SIEF communications also affects dossier submissions since the tonnages provided in the Lead registration dossiers are crucial for defining the Letter of Access costs for joint submissions.
NOTIFY YOUR PRODUCT AND PROCESS ORIENTED RESEARCH AND DEVELOPMENT
Companies exporting substances for Product and Process Oriented Research and Development Projects had questions about the activation of PPORD Notification hanging over their head. In the past, the MoEUCC had published a “Guidance on the Preparation of PPORD Dossiers” for companies that intend to benefit from the registration exemption. Following the relevant Guidance, the PPORD Notification is now integrated into the KKS system by the MoEUCC, and companies can cover their R&D substances without further need for registration.
RGS Group headquartered in Brussels, with a subsidiary in Istanbul and a worldwide partners network, is supplying regulatory compliance services to global corporations located in over 60 countries, notably as Only Representative for EU REACH and Turkish KKDIK. Through the incorporation of ChemAdvocacy Turkey (CATR – www.chemadvocacy.com.tr), Chemservice and RGS have joined forces to offer technical and administrative support for the best management of KKDIK technicalities regarding consortium management, and legal and financial processes of data sharing and LoA administration within KKDIK.
Please do not hesitate to contact RGS in case you have any questions on Turkish chemicals regulations, including CLP and SDS regulations.
REACH Global Services Group