KKDIK PPORD Notification

KKDIK (Turkish REACH): Exemption for Product and Process Oriented Research and Development (PPORD)

Definition of PPORD

PPORD refers to:

"Any scientific development related to product development or the further development of a substance—on its own, in mixtures, or in articles—during which pilot plant or production trials are used to develop the production process and/or test the fields of application of the substance."

Exemption for PPORD under KKDIK

To encourage innovation, KKDIK provides an exemption from the general obligation to register substances used for PPORD.

• Duration of Exemption: 5 years (in accordance with Article 10 of KKDIK).
• Who Benefits:
  • Manufacturers, importers, or manufacturers of articles.
  • This can also include cooperation with listed customers involved in PPORD activities.
• Scope:
  • Substances manufactured or imported in limited amounts for PPORD purposes.

Note: During the exemption period, the amount of substance used for PPORD is not subject to standard registration obligations.

PPORD Notification Process

To benefit from the PPORD exemption, the manufacturer, importer, or article producer must:

1. Notify the Ministry of Environment, Urbanization, and Climate Change of their intention to conduct PPORD.
2. Submit an electronic PPORD notification dossier through the Chemical Registration System (KKS).

Contents of the PPORD Notification Dossier

The PPORD notification dossier must include the following information as per Annex-6 of KKDIK:

1. Identity of the Manufacturer/Importer/Article Producer

• Details must align with the requirements specified in Part 1 of Annex-6.

2. Identity of the Substance

• Information regarding the substance as outlined in Part 2 of Annex-6.
• The person preparing the report must ensure that any possible changes in the substance's composition (predicted during scientific experiments) are included and reported.

3. Classification of the Substance (if applicable)

• Classification details must follow the requirements in Section 4 of Annex-6.

4. Estimated Quantity

• Provide an estimated annual quantity of the substance used for PPORD purposes, as specified in Subsection 3.1 of Annex-6.
• Include the amount of the substance to be manufactured or imported for the calendar year.

Summary of PPORD Exemption Requirements

Conclusion

The PPORD exemption under KKDIK allows manufacturers, importers, and article producers to conduct research and innovation without immediate registration obligations, provided they comply with the notification requirements.

For assistance in preparing PPORD notification dossiers or navigating KKDIK compliance, please contact our experts today!