📢 Under the Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals (KKDIK), chemical manufacturers and importers are required to jointly prepare a registration dossier and submit it to the Ministry of Environment, Urbanization and Climate Change.
As it is known, Only Representatives can add the importer information of the foreign company they represent to the "1.7 Suppliers" section of the registration dossier, or they can prepare the registration dossier without adding the importer information.
The registration dossier of the Only Representative must include all uses of the importers (now downstream users) within the scope of the registration. The Only Representative should maintain a current list of the customers (importers) of the foreign manufacturer in the same supply chain and provide information on the latest update of the safety data sheet for each of these customers and tonnages covered during the registration dossier. During inspections carried out by the Ministry, the Only Representative must provide these documents.
Importers should confirm whether an Only Representative has been appointed for the foreign manufacturer. In addition, it is strongly recommended that importers obtain written confirmation from the Only Representative that the imported tonnage and use are actually covered by the registration scope presented by the Only Representative. This situation will provide the importer with a contact point where they can report their uses as sub-users and also provide the importer with a clear document stating that their imports are actually covered by the registration of the Only Representative.
In order for the importer to compile the safety data sheet when necessary, they must obtain sufficient information from the foreign manufacturer and/or the Only Representative. If requested by the Ministry, the importer in Turkey must be able to prove which imports are covered by the registration of the Only Representative.
Upon the request of the industry, translations of Chemical Safety Reports, which must be submitted in registration dossiers for chemicals of 10 tonnes or more per year, can be uploaded in English. However, the registrants who prefer to upload the Chemical Safety Report in English must also add the Turkish translation version to the registration dossier later, including their uses, exposure scenarios, and risk management measures. On the other hand, all fields in the system regarding "Comprehensive Summaries of the Work" and "Summaries of the Work" to be submitted in the registration dossier will be filled in Turkish.
In order for data sharing under the KKDIK Regulation to function effectively, good management practices must be encouraged and effective functioning of agreements related to sharing such data must be ensured. Therefore, the European Union's Regulation on data sharing, which is parallel to the provisions of the KKDIK Regulation concerning chemical registrations, has been translated in order to provide information to registrants.
ℹ️Source: https://kimyasallar.csb.gov.tr/veri-paylasimi-rehberi-guncellendi/366