KKDIK Late Pre-Registration After 31.12.2020

Key Points Regarding KKDIK Late Pre-Registration

1. Pre-Registration Phase

  • The official pre-registration phase under KKDIK occurred between:
    • 23 December 2017 and 31 December 2020.

2. Late Pre-Registration

  • KKDIK does not include a formal "late pre-registration" phase as in EU REACH.
  • Pre-registration under KKDIK will need to be completed based on the timeline to be officially announced by the Ministry.
  • The details will be communicated through an upcoming circular or similar notice.

3. Full Registration Requirement

For substances not pre-registered by the original deadline, companies must:

  • Submit an inquiry dossier through the KKS (Turkish Chemical Registration System).
  • Complete full registration before the substances can be legally placed on the Turkish market.

4. Deadlines for Full Registration

The updated full registration deadlines are based on annual tonnage and hazard classification:

a) 31 December 2026

  • Substances ≥ 1,000 tonnes/year.
  • Substances ≥ 100 tonnes/year classified as:
    • Aquatic Acute 1 (H400) or Aquatic Chronic 1 (H410).
  • Substances ≥ 1 tonne/year classified as CMR (Category 1A or 1B).

b) 31 December 2028

  • Substances ≥ 100 tonnes/year.

c) 31 December 2030

  • Substances ≥ 1 tonne/year.

5. What Does This Mean for Companies?

  • Although the pre-registration deadlines have not yet been officially determined, they will be specified in the forthcoming Procedures and Principles document published by the Ministry.
  • This document will provide clarity on:
    • Specific timelines for pre-registration.
    • Detailed requirements and processes for compliance.
  • Action Required:
    • Companies should closely monitor official announcements to stay informed.
    • Prepare in advance to meet the upcoming deadlines and ensure compliance.

Key Takeaways for Businesses

  1. No late pre-registration phase under KKDIK.
  2. Inquiry and full registration are mandatory for substances not pre-registered.
  3. Deadlines depend on tonnage and hazard classification.
  4. Await the Ministry’s Procedures and Principles document for final guidance.

Stay proactive to ensure compliance and avoid market disruptions. For further guidance on KKDIK requirements, feel free to reach out!