Dr yaprak Küçükvar, Director of the Istanbul office of REACH Global Services.
Yes, there’s no doubt about it, this is a particularly interesting time to be in regulatory affairs, says one (very busy) expert in environmental regulatory compliance. The EU’s chemical strategy for sustainability on one side, implementation of EU REACH in different regions of the world on the other side, companies are facing several challenges.
For many years now, Dr Yaprak Küçükvar has been supporting non-EU companies navigating the minefield of exporting to the EU.
While the majority of non-EU countries have been steadily moving towards harmony with EU REACH and EU Cosmetics Regulations, meaning an ever-increasing number of businesses in the world today are used to operating within the REACH framework, what we actually have at present is a global patchwork of national regulations that do contain variations.
They might be minor differences, but they can be enough to have a finance director of a SME considering whether the additional hoops are worth jumping through.
And now the UK has rolled its own hoop out into the field, of course.
Dr Küçükvar, Director of the Istanbul office of REACH Global Services, said: “Most countries are trying to harmonise their own regulations with the EU – with the exception of the USA – but each one has slight differences in the manner or approach to implementation.
“In terms of UK REACH, which I’m working on through one of our partners there, non-UK companies that have already complied with EU REACH requirements are now preparing to comply with UK REACH, and to do that they have options to assess depending on the volume of business. A non-UK company can appoint a UK Only Representative to act on their behalf or UK importers may undertake obligation to register their substances.
“This is clearly more regulatory work and more cost to pay for the right to use the EU REACH data and submit registration dossier to the UK HSE. Companies may prefer to act through their subsidiary offices in the UK.”
The decision on whether it was still worth exporting to the UK was down to each individual company concerned, and the picture was coloured as much by indirect exports as direct exports.
“A company might sell ingredients to, say, Germany, where they are mixed and formulated and then sold on to the UK,” she said, “so those chemicals need to be somehow registered by an actor in the supply chain to comply with UK regulations too.
“Many SMEs are trying to analyse their options and the cost of compliance, working out the value of their direct and indirect exports to the UK and weighing up whether it is worth the additional cost.”
The big question was whether it was worth exporting to the ‘one’, when exporting to the EU gave businesses access to 26 countries in one fell swoop.
But, she said: “The UK is still a good export partner and an important market for many countries; each company has various supply chains to analyse and they will take a decision based on their export volumes and the cost of compliance.”
A founding manager of REACH Global Services Group, which has its head office in Brussels, Dr Küçükvar has over 15 years’ experience of regulatory compliance under her belt, focused specifically on chemicals and the related management policies in both the EU and Turkey.
She set off down that particular track while studying for her PhD in chemistry at the University of Newcastle, in northern England. During the wide-ranging course that also covered physical and environmental chemistry, she discovered a passion for environmental sciences.
After graduation, she duly joined a pharmaceutical company in Istanbul, working in due diligence teams to expand the product line and preparing the regulatory compliance dossiers for various products.
Then in 2007, when the EU published its first REACH framework which inevitably also effected non-EU companies Istanbul Mineral and Metals Exporters’ Association decided to establish a Turkish REACH helpdesk. Dr Küçükvar, helped initiate REACH Helpdesk activities to create awareness for manufacturers, contributing with her REACH knowledge and interest in chemicals sectors.
“One of the most important projects I worked on for the association was the launch of an Only Representative company (OR) in Europe to help non-EU companies comply with REACH legislation,” she said.
“I focused on the regulatory obligations of an OR and services that non-EU companies require to comply with EU REACH , the office was opened in Brussels, and that was the start of REACH Global Services Group.”
She has managed the sister office in Istanbul from the beginning and represents the headquarter office in Brussels. Although they focus predominantly on REACH, they do also work on chemical regulations compliance around the globe.
“At the minute, the Turkish Ministry of Environment and Urbanisation is implementing EU REACH regulation,” she said. “There are a lot of similarities between the two; EU REACH and Turkish REACH abbreviated as KKDIK but while companies had a 10 year time frame to complete the registrations in the EU, Turkey has given companies 3 years to submit the registrations regardless of the volume or classification. All substances will be KKDIK registered by the end of 2023 in the Turkish market.
Part and parcel of her job is keeping a close eye on what can be very fluid national and international markets. Indeed, nurturing a good understanding of the law – many laws – is as important as understanding the chemistry, she said with a wry smile. Dr Küçükvar is also responsible for her company’s operations in Japan, Korea, China and Taiwan.
Globally, RGS Group works with more than 1000 manufacturers located in over 50 countries, overcoming critical supply chain obstacles and smoothing the way to compliance.
And as we said at the beginning, she does feel this is a pivotal time to be working in regulatory compliance, because every day, somewhere in the world, something changes.
It keeps her on her toes. “We work across all chemical sectors, from metals to speciality chemicals to paint to additives, so yes, I am always analysing,” she said.
“The world is always changing and chemicals are important to all of our lives, as are the effects of air pollution and global warming and the care we need to take in how we use chemicals, so I think we will be having many discussions around the subject of compliance for many years to come.
“Our area of expertise generally in the field has grown a lot over the past 20 years, but it will grow hugely again in the next 20, so I am grateful to be in this business – I love being in this business – at such an interesting time.”