Understanding KKDIK Turkish REACH

Understanding KKDIK (Turkish REACH)

KKDIK is the Turkish Regulation on the Registration, Evaluation, Authorisation, and Restriction of Chemicals, adopted from EU REACH to:

  • Protect human health and the environment from risks posed by chemicals.
  • Enhance the competitiveness of the Turkish chemicals industry.
  • Promote alternative methods for hazard assessment to reduce animal testing.

KKDIK applies to all chemical substances, including those used:

  • In industrial processes.
  • In daily life, such as cleaning products, paints, and articles like clothes, furniture, and electrical appliances.

The regulation impacts most companies across Turkey by placing the burden of proof on them to:

  • Identify and manage risks linked to substances they manufacture or market.
  • Demonstrate to the Ministry of Environment, Urbanization, and Climate Change (MoEU) that substances can be safely used.
  • Communicate risk management measures to downstream users.

If risks cannot be managed, authorities can:

  • Restrict or ban the use of substances.
  • Encourage the substitution of hazardous substances with safer alternatives over time.

KKDIK came into force on 23 June 2017.

How Does KKDIK Work?

KKDIK establishes procedures for collecting and assessing data on the properties and hazards of chemical substances.

Key Processes:

  1. Registration:

    • Companies must register their substances.
    • Collaboration is required among companies registering the same substance.

  2. Evaluation:

    • MoEU evaluates the compliance of registration dossiers.
    • Selected substances are further assessed to address concerns for human health or the environment.

    Timeline:

    • Evaluation period: 1 January 2021 – 31 December 2023.

  3. Authorisation:

    • MoEU’s scientific committees assess whether the risks of substances can be managed.
    • Substances with unmanageable risks may be banned, restricted, or subjected to prior authorisation.

  4. Restriction:

    • Authorities can impose restrictions on the use of hazardous substances to reduce risks.

KKDIK’s Impact on Companies

KKDIK affects a broad range of companies across various sectors, even those not directly involved in chemical production.

Key Roles Under KKDIK:

1. Manufacturer

  • If you manufacture chemicals for your own use, for supply, or for export, you have key responsibilities under KKDIK.

2. Importer

  • If you import chemicals into Turkey (including mixtures or finished products such as clothes, furniture, or plastics), you are responsible for compliance with KKDIK.

3. Downstream Users

  • Most companies use chemicals, often without realizing it.
  • You must check your obligations under KKDIK if you handle chemicals as part of your industrial or professional activities.

4. Companies Established Outside Turkey

  • Non-Turkish companies are not directly bound by KKDIK.
  • However, their products entering the Turkish market must comply with KKDIK.
  • Compliance responsibility lies with:
    • Importers established in Turkey.
    • An Only Representative (OR) appointed in Turkey to act on behalf of non-Turkish manufacturers.

Conclusion

KKDIK imposes significant obligations on manufacturers, importers, and downstream users to ensure chemical safety while encouraging innovation. Compliance requires a clear understanding of your role, responsibilities, and timelines under KKDIK.

For guidance on KKDIK compliance, including registration, authorisation, and risk management, reach out to our experts today!