What is KKDİK (Turkish REACH) ?

What is KKDIK (Turkish REACH)?

KKDIK stands for Kayit (Registration), Değerlendirme (Evaluation), İzni (Authorization), and Kısıtlanması (Restriction) of Kimyasalların (Chemicals). It is the Turkish adaptation of the EU REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) regulation. The primary goal of KKDIK is to regulate the manufacture, import, and use of chemical substances to ensure a high level of protection for both human health and the environment.

The regulation mandates that manufacturers and importers operating in Turkey register substances they produce or import in volumes of 1 tonne or more per year. It also requires a thorough assessment of the properties and potential risks associated with these chemicals.

Key features of KKDIK include:

  • Registration: Organizations must provide detailed information about substances, including their properties, uses, and safety measures, to the Ministry of Environment, Urbanization, and Climate Change.
  • Evaluation: Authorities review submitted information to assess potential risks to health and the environment.
  • Authorization: Substances with identified risks are subject to authorization, meaning their use is restricted unless specific permission is granted.
  • Restriction: Measures are imposed to limit or prohibit the production, sale, or use of certain substances deemed hazardous.

The KKDIK regulation came into effect on June 23, 2017, replacing the previous Chemical Inventory and Control Regulation (CICR). It aligns closely with REACH to facilitate trade and ensure harmonization with EU chemical safety standards.

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Why Was KKDIK Introduced?

  • Turkey aimed to align its chemical regulations with EU standards as part of its future EU accession goals.
  • KKDIK fills the gap created by earlier laws that were transpositions of older EU directives (e.g., EC 99/45 and Directive 76/769/EC).
  • It ensures that chemicals manufactured, imported, or placed on the Turkish market comply with modern regulatory frameworks.

Scope of KKDIK

KKDIK covers:

  • Manufacturing, importing, placing on the market, or using substances either:
    • On their own
    • In a mixture
    • In an article (if intended for release)
  • Substances in quantities ≥1 ton/year must be registered through Turkey's Chemical Registration System (CRS).

Key Obligations Under KKDIK

  1. Registration:

    • Manufacturers or importers producing/importing ≥1 ton/year must register substances via the Ministry of Environment's Chemical Registration System (CRS).
    • Updated Deadlines for Registration:
      • By December 31, 2026:
        • Substances ≥1,000 tonnes/year.
        • Substances ≥100 tonnes/year classified as Aquatic Acute 1 and/or Aquatic Chronic 1 (H400, H410).
        • Substances ≥1 tonne/year classified as CMR Category 1A or 1B.
      • By December 31, 2028:
        • Substances ≥100 tonnes/year.
      • By December 31, 2030:
        • Substances ≥1 tonne/year.
  2. Only Representative (OR) Requirement:

    • Non-Turkish companies must appoint a KKDIK Only Representative (OR) to comply with registration obligations.
    • ORs represent foreign manufacturers in Turkey.
  3. Risk Management:

    • The responsibility to manage risks lies with manufacturers, importers, and downstream users.
  4. Pre-SIEF Notification:

    • Pre-registration (pre-SIEF) was mandatory before December 31, 2020, including:
      • Substance identity (Annex-6)
      • Role in the supply chain
  5. Alternatives for Testing:

    • KKDIK promotes alternative methods to animal testing when assessing hazards.

KKDIK Timeline

Deadline: December 31, 2026

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

Deadline: December 31, 2028

  • Substances ≥100 tonnes/year

Deadline: December 31, 2030

  • Substances ≥1 tonne/year

Impact on Businesses

  • Companies exporting chemicals to Turkey must:
    • Appoint an Only Representative (OR) if they’re not based in Turkey.
    • Ensure compliance to avoid barriers to trade in the Turkish market.
  • KKDIK increases regulatory transparency and accountability while enhancing competitiveness of the Turkish chemical industry.

Conclusion

KKDIK aligns Turkey’s chemical regulations with EU REACH, ensuring safety and sustainability in the chemical supply chain. Compliance is critical for companies operating in or exporting to Turkey. If you need a streamlined process for registration, Lisam Systems provides tailored Only Representative (OR) and regulatory monitoring services to meet KKDIK requirements.