KKDİK Industry Obligations

KKDIK Industry Obligations

Drawing upon the extensive experience of our specialists, gained in helping companies of all kinds in every industry sector, this service is just what you need for that expert support and peace of mind. We can help you at any stage of the SEA (Turkish CLP) or KKDİK (Turkish-REACH) compliance process, from the first steps of getting to grips with the legislation, to helping you assess your progress towards compliance or assisting you audit your own supply chain. Our consultancy service is designed just for your needs..

Registration

Registrant: Manufacturer, importer and only representative;
Target: all substances manufactured or imported greater than 1t/y, including substances intended to be released from articles.
KKDİK Pre-registration (pre-SIEF) deadline: 31 Dec 2020
KKDİK Registration deadline: 31 Dec 2023
Four tonnage bands are: 1-10t/y, 10-100t/y, 100-1000t/y, 1000t/y+;
Data requirement and risk assessment report similar to REACH EU.
Reduced registration requirements for substances used for product and process-oriented research and isolated intermediates.
For polymers, monomers shall be registered if the volume of monomer exceeds 1t/y.
Joint submission is mandatory.

Turkish SDS (GBF)

16-sections GHS compliant safety data sheet (MSDS-GBF);
Must be in Turkish,
Must be prepared by certified Turkish SDS authors or Chemical Safety Assessors.

Restriction

Must comply with restriction conditions set out in annex 17;
Annex 17 similar to  REACH Annex XVII Restricted Substances List.

Authorization

Substances on Annex-14 cannot be manufactured, imported or used unless an authorization has been granted;
Candidate substances for inclusion in annex 14 similar to  EU SVHC candidate list;
Annex 14 similar to  REACH Annex XIV Authorization List

Turkish REACH (KKDİK) and EU REACH Differences

KKDIK requires that only trained and qualified experts sign off registrations and notifications.
Other than that, there are no major differences between Turkish KKDIK regulation and EU REACH.
To comply with KKDIK regulation, companies mainly need to do the following 3 things:
Pre-register (pre-SIEF) /register applicable substances greater than 1t/y before given deadline. 
If your company is based outside of Turkey, you may need to appoint a local only representative.
Ensure that your safety data sheets are compliant.
Annex XVIII explains CONDITIONS FOR RECEIVING CERTIFICATE OF COMPETENCY OF CHEMICAL ASSESSMENT EXPERT.
Monitor the list of substances subject to authorization on annex 14 and the list of restricted substances on annex 17.