KKDIK PRE-REGISTRATION DEADLINE; 31 DECEMBER 2020
The clock is ticking for all chemical manufacturers in Turkey and global companies with putting chemicals on the Turkish market. By the end of 2020, all substances must have been pre-registered according to the Turkish REACH-like regulation, KKDIK. The exemptions from the obligation to (pre-)register must be reviewed carefully and it is not hard for companies to make this decision as the same criteria then REACH for exemptions are applicable under KKDIK. If a substance which has not been pre-registered before is placed on the Turkish market for the very first time after 2020, the system still allows such companies to pre-register.
Manufacturer or importer of a substance on its own or in a mixture of quantities ≥1 tonne/year shall submit a pre-registration to the Ministry of Environment and Urbanisation (MoEU) until 31 December 2020.
The companies pre-registering to the MoEU’s Chemicals Registration System, abbreviated as KKS, do automatically join the corresponding Substance Information Exchange Forum; MBDF. MBDF enables all potential registrants and data holders to interact and prepare for registration. Registration period is only 3-year long and even now more than 18,000 substances’ pre-registrations are completed by over 850 companies according to the latest figures of MoEU. That corresponds to more than 77.000 pre-registrations. There is no doubt that some companies, especially importers and formulators, pre-registered to be on the safe side. However, the expectations of the Turkish importers and distributors are high that their non-Turkish suppliers do register via an Only Representative or through their Turkish subsidiaries. Turkish importers are in communications with their suppliers to create awareness for KKDIK and seek compliance.
KKS is under permanent improvement and MoEU announced on their website that the new version of KKS which is more user friendly will be available soon and the updated KKS Manuals will be published simultaneously. It is expected that this new version will have more functionalities and be in line with the latest version of IUCLID. This improvement is managed under the IPA (Instrument for Pre-Accession Assistance) co-financed by the European Union and the Republic of Turkey that started on 1 November 2019. The ongoing IPA project is a European programme for EU candidate countries and the aim is to harmonise Turkish chemicals regulations with the EU. Therefore, continuous updates to the KKDIK, SEA Regulations and online KKS system are expected.
31 DECEMBER 2023 SINGLE REGISTRATION DEADLINE
It is clear from REACH experience that the success of the registration period is not only dependent on the good co-operation of the potential registrants but also on the efficient use of the KKS without interruption, particularly during the registration period. Especially when considering that the registration dossiers will be created online under KKS in Turkish language, meaning several users will be using KKS at the same time. Moreover, there is a single deadline for all substances to be registered regardless of the tonnage band or the hazard classification.
Reach Global Services team of experts transferred over twelve-year-long of their EU REACH experience into practical solutions for non-Turkish companies to comply with Turkish chemicals regulations, KKDIK and SEA. Do not hesitate to contact RGS if you need more details on our services. We can assess your compliance status and build up tailor-made solutions for your company within our due diligence approach.
Dr.Yaprak Yüzak Küçükvar
REACH Global Services Group
Director, Global Regulatory Affairs & Product Stewardship