KKDİK Industry Obligations

Registration

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

Safety Data Sheets (GBF/SDS)

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

Restriction

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

Authorization

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

Turkish REACH (KKDİK) and EU REACH Differences

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

Having Questions?

We provide KKDİK consultancy services. If you have questions or need any help, please contact our KKDİK specialist team via info.tr@lisam.com