Registrant: Manufacturer, importer and only representative;
Target: all substances manufactured or imported greater than 1t/y, including substances intended to be released from articles.
KKDİK Pre-registration (pre-SIEF) deadline: 31 Dec 2020
KKDİK Registration deadline: 31 Dec 2023
Four tonnage bands are:
Data requirement and risk assessment report similar to REACH EU.
Reduced registration requirements for substances used for product and process-oriented research and isolated intermediates.
For polymers, monomers shall be registered if the volume of monomer exceeds 1t/y.
Joint submission is mandatory.
Safety Data Sheets (GBF/SDS)
16-sections GHS compliant safety data sheet (MSDS-GBF);
Must be in Turkish,
Must be prepared by certified Turkish SDS authors or Chemical Safety Assessors.
Must comply with restriction conditions set out in annex 17;
Annex 17 similar to REACH Annex XVII Restricted Substances List.
Substances on Annex-14 cannot be manufactured, imported or used unless an authorization has been granted;
Candidate substances for inclusion in annex 14 similar to EU SVHC candidate list;
Annex 14 similar to REACH Annex XIV Authorization List
Turkish REACH (KKDİK) and EU REACH Differences
KKDIK requires that only trained and qualified experts sign off registrations and notifications.
Other than that, there are no major differences between Turkish KKDIK regulation and EU REACH.
To comply with KKDIK regulation, companies mainly need to do the following 3 things:
Pre-register (pre-SIEF) /register applicable substances greater than 1t/y before given deadline.
If your company is based outside of Turkey, you may need to appoint a local only representative.
Ensure that your safety data sheets are compliant.
Annex XVIII explains CONDITIONS FOR RECEIVING CERTIFICATE OF COMPETENCY OF CHEMICAL ASSESSMENT EXPERT.
Monitor the list of substances subject to authorization on annex 14 and the list of restricted substances on annex 17.
We provide KKDİK consultancy services. If you have questions or need any help, please contact our KKDİK specialist team via firstname.lastname@example.org