The Ministry of Environment, Urbanization and Climate Change (MoEUCC) has recently sent a warning message to all potential registrants; “Chemicals cannot be placed on the Turkish market after the deadline of 31 December 2023 unless they are registered.” This confirms once again that registration dossiers should be prepared and submitted to MoEUCC as soon as possible.

Recently, there is a lot of communication traffic within the SIEFs in Turkey. However, fifteen months after the pre-registration deadline of 31 December 2020, many substances have not been registered by the lead registrants yet.

The lead registrants declared to the Ministry their lead role through online Chemical Registration System (KKS) if there is no objection from SIEF members. In case there are more than one lead candidates, members voted for them. On the other hand, for a significant number of substances no lead candidate appears in KKS. Some of the leaders have already prepared and submitted their dossiers to the Ministry. The process takes quite much time considering dossier creation processes on KKS, i.e. Chemical Safety Report preparation & certification, translation and data licensing for Turkey. One should keep in mind that it is also taking some time for the Ministry to review and approve the dossiers. Therefore, the Ministry is urging the manufacturers, importers and Only Representatives to prepare their registration dossiers and not to leave their submissions to the last minute.

Further announcement on dossier assessments by the Ministry

The Ministry reviews submitted registration dossier and if there is any missing information, the registrant receives a feedback through KKS with a list of requested corrections & updates which need to be done within 7-10 days. If requested by the registrant, the Ministry might extend the given deadline. The Ministry highlights two important points in its latest announcement on update procedures in KKS:

  • Updates must be processed on submitted substances page in KKS. The registrants should not edit &submit the dossier in substance management page as it will create a new registration submission.
  • If the dossier cannot be updated within the given deadline, it will be rejected as per in Article 20 (2) (ç) of KKDIK and the registration fee will not be reimbursed.

KKS still allows companies to “pre-register”

Unlike EU REACH, there is no “late pre-registration” mechanism according to KKDIK. Late pre-registration terminology is not used by the Ministry. But currently the Ministry’s KKS online system still allows companies to pre-register after the deadline of 31st December 2020. This particularly aims the manufacturers, Only Representatives or importers who are placing chemicals on the market for the very first time as of 2021. Other companies who already placed chemicals on the market had to meet the deadline of 31 December 2020. If you already placed the substance on the market and pre-register now, this will be considered as a pre-registration beyond the official deadline and the date of the submission will clearly be seen on KKS by the Ministry. However, you will be pre-registering with “good intention” to meet the regulation and Ministry is tolerant for such late compliances.

Potential co-registrants are waiting for SIEF agreement & LoA fee information

As there are ongoing discussions between data owners in EU and Lead registrants in Turkey, although the lead registrants do prepare their dossiers in KKS, they cannot submit before getting the right to use their REACH data for KKDIK. A few EU consortia have updated their existing data sharing agreements for UK and Turkey and determined LoA costs. Lately, potential co-registrants are wondering the timeline in order to not the leave their submissions to the last minute and waiting for other details to be clarified such as; substance information profiles (SIPs) and SIEF agreements as well as Letter of Access (LoA) fees.

Data sharing, cost modeling, determination of LoA fees, financial management and legal issues are all needed to be well and urgently assessed under KKDIK. Since 2008, as RGS Group of companies, we are assisting manufacturers in over 55 countries to comply with international chemicals legislations. We joined our forces with Chemservice Group to establish ChemAdvocacy Turkey (CATR) in April 2021 to independently coordinate the administrative and technical processes of the SIEF management with the Lead Registrants, and the relevant consortia in the EU. Currently, CATR is transposing its EU REACH, K-REACH, UK REACH experience on Consortia Management, Data Management, Financial Management into KKDIK.

If you have any questions on Turkish chemicals regulations, do not hesitate to contact RGS for more details on our services.

REACH Global Services Group

Hilal Sevinc

Deputy Director