KKDİK Industry Obligations

KKDIK Industry Obligations

Our consultancy service, built upon extensive expertise across various industries, is tailored to provide you with the support you need to ensure seamless compliance with both KKDIK (Turkish REACH) and SEA (Turkish CLP) regulations. Whether you are starting your compliance journey, evaluating your progress, or auditing your supply chain, we are here to offer expert guidance and peace of mind.

1. Registration Requirements

Who Must Register?

• Registrants: Manufacturers, importers, and only representatives.
• Scope: Substances manufactured or imported in quantities ≥ 1 tonne/year, including substances released from articles.

Key Deadlines

The updated registration deadlines depend on tonnage and hazard classification:

• 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).

• 31 December 2028:

  • Substances ≥ 100 tonnes/year.

• 31 December 2030:

  • Substances ≥ 1 tonne/year.

Key Requirements

• Four Tonnage Bands:
  • 1-10 t/y, 10-100 t/y, 100-1,000 t/y, and 1,000+ t/y.
• Data Requirements: Registration requires data and risk assessment reports, similar to EU REACH.
• Reduced Requirements: Apply for substances used for PPORD (Product and Process Oriented Research) and isolated intermediates.
• Polymers: Monomers must be registered if monomer quantities exceed 1 tonne/year.
• Joint Submission: Mandatory for companies registering the same substance.

2. Turkish Safety Data Sheets (SDS/GBF)

• Format: 16-section GHS-compliant Safety Data Sheet (SDS).
• Language: Must be prepared in Turkish.
• Certification: SDS must be authored and signed by a Certified Turkish SDS Author or Chemical Safety Assessor.
• Compliance: SDSs must comply with KKDIK Annex II requirements.

3. Restriction Requirements

• Conditions: Companies must comply with restrictions set out in Annex 17.
• Scope: Annex 17 aligns closely with the REACH Annex XVII Restricted Substances List.

4. Authorization Requirements

• Annex 14: Substances listed in Annex 14 cannot be manufactured, imported, or used unless an authorization has been granted.
• Candidate List: Substances for Annex 14 are similar to the EU SVHC (Substances of Very High Concern) Candidate List.
• Authorization Process: Applications are submitted through the KKS System and assessed by MoEU.

5. Key Differences Between KKDIK and EU REACH

While KKDIK closely aligns with EU REACH, the following distinctions apply:

1. Qualified Experts:

   • KKDIK requires that trained and certified Chemical Safety Assessors prepare and sign off on all registration dossiers and notifications.

2. Main Compliance Steps:

   • Pre-Register / Register all applicable substances ≥ 1 tonne/year by the specified deadlines.
   • Non-Turkish companies must appoint a local Only Representative (OR) to fulfill their obligations.
   • Ensure SDSs comply with KKDIK Annex II and are prepared in Turkish.

3. Annex XVIII:

   • Explains the conditions for receiving certification of Chemical Safety Assessors in Turkey.

4. Ongoing Monitoring:

   • Regularly monitor:
     • Annex 14: Substances subject to authorization.
     • Annex 17: Restricted substances list.

Summary of Key Deadlines

Why Choose Lisam Systems?

Our expert consultants provide tailored services to ensure your company meets KKDIK compliance obligations:

• Registration and Pre-Registration Services.
• SDS Authoring and Compliance Solutions.
• Authorization and Restriction Management.
• Only Representative Services for non-Turkish companies.
• Supply Chain Compliance Audits.

Contact Us Today

Ensure full compliance with KKDIK deadlines and requirements with the expert support of Lisam Systems Türkiye.

📍 Locations:

• Istanbul Office: +90 (212) 705 62 62
• Izmir Office: +90 (232) 282 10 35
• Gebze Office: +90 (262) 32 000 32
  📧 Email: info.tr@lisam.com