Turkey GHS Implementation

Turkey GHS Implementation (SEA Regulation)

Turkey adopted the Globally Harmonized System (GHS) for classification, labeling, and packaging of chemicals through the SEA Regulation (Turkish CLP), which aligns closely with the EU CLP Regulation (EC No. 1272/2008).

The By-Law on Classification, Labelling, and Packaging of Substances and Mixtures, published on 10 December 2020 in the Official Gazette No. 31330 (Duplicate Issue), updated and replaced earlier versions to maintain harmonization with the latest amendments (13th ATP) to the EU CLP Regulation.

Key Highlights of the New By-Law

Scope

The By-Law applies to:

  • Substances and mixtures placed on the Turkish market.
  • Exemptions include:
    • Pharmaceuticals
    • Cosmetics
    • Food and feed
    • Radioactive substances
    • Non-isolated intermediates
    • Waste
    • Chemicals for national defense

Annexes of the By-Law

The new By-Law incorporates Annexes similar to the EU CLP Regulation, ensuring alignment with 13th ATP:

  1. Annex I: Criteria for Classification and Labelling

    • Provides rules for identifying hazards (physical, health, and environmental).

  2. Annex II: Special Rules for Labeling and Packaging

    • Requirements for:
      • Hazard pictograms
      • Signal words
      • Hazard statements (H-statements)
      • Precautionary statements (P-statements)
    • Packaging standards for chemicals (e.g., child-resistant closures).

  3. Annex III: List of Hazard Statements

    • Details H-statements (e.g., H300: Fatal if swallowed).

  4. Annex IV: List of Precautionary Statements

    • Includes P-statements for handling, storage, and disposal (e.g., P102: Keep out of reach of children).

  5. Annex V: Hazard Pictograms

    • Standardized GHS pictograms for labeling requirements.

  6. Annex VI: Harmonized Classification and Labelling List

    • Turkey's harmonized list of substance classifications aligns with EU CLP Annex VI, with exceptions (e.g., boric compounds).

Key Deadlines for Compliance

  • 1 June 2015: GHS fully enforced for substances.
  • 1 June 2016: GHS fully enforced for mixtures.
  • 31 December 2023: Transition deadline for preparing Safety Data Sheets (SDSs) in compliance with:
    • KKDIK Annex II (aligned with EU Regulation 453/2010).

Notable Additions

  1. C&L Notification

    • Substances placed on the Turkish market must be notified to the C&L Inventory within 1 month.

  2. Poison Centre Notification (PCN)

    • As per the draft regulation, Poison Centre notifications will be managed by the Ministry of Health starting January 2025.

  3. SDS Requirements

    • SDSs must be in Turkish language and prepared by certified professionals.
    • Certification details must appear in Section 16 of the SDS.

Conclusion

The 10 December 2020 By-Law ensures Turkey remains harmonized with EU CLP developments, particularly the 13th ATP. Chemical companies must update their compliance strategies to align with the latest requirements, including classification, labeling, and SDS obligations.

For assistance with:

  • SDS Preparation in compliance with KKDIK and SEA Regulation
  • C&L Notifications
  • GHS Labeling and Packaging requirements

Contact us today to stay compliant with Turkey’s evolving chemical regulations!