KKDIK (Turkish REACH) requires companies to pre-register and register substances which are manufactured or placed on the Turkish market either on their own, or in mixtures or in articles with an intended release which are equal or higher than 1 ton per year. Companies exporting chemicals to Turkey can appoint an Only Representative (OR) to submit the KKDIK (pre) registration and the CLP notification on their behalf. Compliance with KKDİK (Turkish REACH) is mandatory for continued sales of chemicals and products in Turkish market. Up to thirty thousand existing chemicals will be licenced of being pre-registered. Lisam System's pre-SIEF (KKDİK pre-registration) service offers full support to complete this first big phase in KKDİK (Turkish REACH) compliance by defining your obligations for KKDİK (Turkish REACH), on a company-wide level, and for each substance under scope.
KKDIK registration is divided in two stages, named Pre-SIEF (Pre-registration) and Registration.
Pre-registrations and Registrations are submitted in an online portal through the Chemical Registration System tool. The pre-registration started from 23 December 2017 and all pre-registrations needs to be submitted before 31 December 2020. The KKDIK registration period will start on 31 December 2020.
Late KKDIK pre-registrations for the substances greater than 1 TPA will be acceptable after 31.12.2020 in Turkey KKS portal.
If the pre-registration (PRE-SIEF) has been completed by 31 December 2020, substances can be placed or imported into Turkey until 31 December 2023. After 31 December 2023, substances which have not been registered under KKDIK (Turkish REACH) will not be permitted to be manufactured or imported into Turkey with a volume equal to or greater 1 ton per annum.
1. Will there be fees for the pre- (SIEF) notification phase?
Pre-(SIEF) is free. There is actually no pre-registration term but a "pre-SIEF notification", which is free.
2. If a company supplies to the Turkish market currently is it mandatory to pre-SIEF?
Yes, indeed. If you supply your substance at >1tpa before the 31st December 2020 deadline, the substance has to be pre-SIEF-ed in order to make use of SIEF discussions for registration. Until the end of the registration period, 31st Dec 2023, you need to pre-SIEF notify to be able to register.
3. What happens if a company wishes to manufacture or import a substance for the first time at >1tpa after the pre-SIEF deadline of 31 December 2020?
If a substance is supplied to the Turkish market for the first time since KKDIK entered into force at >1tpa in 2021, a pre- SIEF notification can be submitted until the end of the registration period in order to be part of the pre-SIEF (ön-MBDF) discussion and MBDF (SIEF) joint registration.
4. Can a company decide not to submit a pre-(SIEF) notification, then later change their mind? e.g., they don’t submit a pre- (SIEF) notification by the end of 2020, but then decide to do so in June 2021.
According to KKDIK Regulation; for substances manufactured or imported on their own or in a mixture before 31/12/2023, if the annual amount is one ton or above, the registration provisions of the Regulation are applied between 31/12/2020 and 31/12/2023 (Provisional Article 2). In accordance with KKDIK Regulation; For manufacturers and importers to make joint registration; firstly, pre-SIEF must be sent via KKS. Companies that have sent pre-SIEF can access the contact information of other companies that have sent the pre-SIEF of the same substance by making inquiries, so that they can contact with the manufacturers and importers of the same substance regarding the data and cost sharing issues required for registration before the registration process. In this respect, it is important that pre-SIEFs are sent before 31/12/2020, when the registrations will start, for the effective operation of the joint registration process. However, due to the registration process continuing until 31/12/2023 and the system being active for substances to be placed on the market after 31/12/2020, the pre-SIEF module will not be closed and will continue to function after 31/12/2020. This issue applies to all substances covered by the regulation. The penal provisions on the subject will be applied within the scope of registration and from the deadline for registration.
5. If a company has to submit pre-SIEF notification for a first-time supply in 2021 supply > 1 tpa, does this have to be done before exceeding 1 tpa or within 6 months of exceeding?
No period of time is prescribed by the authority.
6. When does the ability for pre-(SIEF) notification end for first time manufacturers and importers? Is it the end of 2023?
Yes! "pre-SIEF notification" will be possible until the end of the whole KKDIK registration period! Substances to be produced or imported in quantities of one tonne or more per year for the first time after 31/12/2023 must also be registered before they are manufactured or imported in quantities of one tonne or more per year. Before the registration of these substances, an inquiry file will be required to determine whether a registration or other type of research has been submitted for the same substance in order to apply data sharing mechanisms.
7. How do we know who has submitted a pre-SIEF notification already for a given substance?
This can only be seen through Chemical Registration System, when potential registrants submit pre- SIEF notifications for the same substance(s)
8. Is there the ability to claim CBI on substance identity information when pre-SIEF-notifying substances? Some of these may perhaps be claimed as CBI elsewhere in the world and if the full substance identity is published under KKDIK it could undermine efforts made to protect CBI elsewhere in the world.
There is no way but one to protect CBI within the pre-SIEF process and this would be to request an alternative name.
There are no terms such as “phase-in substances” or “NONS” in KKDIK.
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