Understanding KKDIK (Turkish REACH)

Navigating complex chemical regulations like KKDIK (Turkish Regulation on Chemicals Registration, Evaluation, Authorisation, and Restriction) and REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) can be challenging for any business. That’s why we offer specialized compliance services to assist you in meeting your regulatory obligations.

Understanding KKDIK and Its Relation to REACH

KKDIK is often likened to the EU’s REACH regulations, which are well-established and familiar to many businesses. This similarity is not coincidental, as KKDIK has been harmonized with the core principles of REACH. If you’ve previously dealt with REACH regulations, you’ll find the transition to KKDIK relatively straightforward.

Pre-registration and Registration Obligations: Key Deadlines

KKDIK sets clear obligations for the pre-registration and registration of substances produced or imported into Turkey. If your business deals with substances in quantities equal to or exceeding 1 ton per year, you must pre-register them by December 31, 2020, and complete the registration process by December 31, 2023.

To streamline this process, all stakeholders, including Manufacturers, Importers, Formulators, and Only Representatives, need to provide detailed information about the substances and their role in the supply chain. The Ministry’s Chemical Registration System Portal is the platform for submitting this information. For businesses that have previously submitted a Classification-Inventory Notification (SEA), this data can be easily transferred to the MoEU’s notification portal.

The registration process involves submitting a comprehensive substance registration dossier to the MoEU. The window for this process opens after the December 31, 2020 pre-registration deadline and concludes on December 31, 2023. It’s important to note that, as with EU REACH, there are no specific deadlines for tonnage bands above 1 ton per year. Additionally, businesses located outside of Turkey can appoint an Only Representative (OR) within Turkey to manage notification and registration.

Article-Related Obligations: What You Need to Know

Under KKDIK, there are specific obligations regarding substances present in articles:

a) Producers and importers are required to notify the MoEU about substances listed on the Candidate list, mirroring the EU REACH regulations. This notification is necessary when two conditions are met:
– The substance is present in their relevant articles above a concentration of 0.1% weight by weight.
– The substance is present in these relevant articles in quantities totaling over one ton per year.

b) Producers and importers must also notify and register substances intended to be released from their articles in quantities equal to or exceeding 1 ton per year.

Application for Authorisation: A Transparent Process

KKDIK’s approach to authorisation aligns with the REACH Regulation. The MoEU will determine the list of substances to be added to Annex XIV, and this list will be accessible on the Ministry’s website. To apply for authorisation, businesses can use the Ministry’s Chemical Registration System Portal. Applications will be thoroughly assessed by the MoEU, and decisions on authorisation requests will be communicated within 10 months.

We are here to provide comprehensive KKDIK and REACH compliance services, ensuring that you can efficiently meet your regulatory obligations. Our team of experts is ready to guide you through the entire process, making complex regulations understandable and manageable for your business. Don’t hesitate to contact us for more information and assistance. Your compliance is our priority.