Turkey Publishes REACH Regulation

Turkey Publishes REACH Regulation

On June 23, 2017, the Turkish Ministry of Environment and Urbanization (MoEU) published its own version of the European Union’s (EU) REACH Regulation. The regulation is called ‘KKDIK’, which is the REACH regulation acronym written in Turkish.

The regulation, which replaces three existing chemical regulations, is due to come into effect on December 23, 2017. This leaves companies manufacturing in or importing into Turkey with very little time to prepare their supply chains for compliance.

KEY TAKEAWAYS:

  1. As with EU REACH, KKDIK requires the collection of complex data from the supply chain and the provision of 16-heading GHS Safety Data Sheets (SDS) to maintain compliance. These must be written in Turkish.
  2. If your company is based outside of Turkey, you may need to appoint a local only representative to register your substances in advance of the relevant deadlines.
  3. Best practice is to stay informed of the substances subject to authorization and restriction in Annexes 14 and 17 (respectively) to ensure ongoing compliance.
  4. Registrations and notifications can only be approved by qualified experts who have undergone a minimum of 64 hours of training, among other requirements (Annex 18). This is said to be the only major difference between the EU and Turkish REACH regulations.

Frustrated by disorganized REACH compliance? Concerned about KKDIK requirements? Our REACH module makes compliance simple. Learn more here. 


Registration & Evaluation: The deadline for the pre-registration of substances is December 31, 2020, and the final registration deadline is December 31, 2023. As with the EU REACH Regulation, KKDIK requires companies to register all substances manufactured in Turkey or imported into the country at quantities greater one ton per year, in line with the four listed tonnage band deadlines. Registration can be performed by manufacturers, importers and ‘only representatives’.

Authorization & Restriction: The restricted substances found in Annex 14 of KKDIK (similar to REACH Annex XVII of REACH) cannot be manufactured, imported or used unless an authorization has been granted for that specific substance and its particular usage. The Candidate List of substances to be included in Annex 14 is akin to the EU Substances of Very High Concern (SVHC) Candidate List.

Scope: The Turkey REACH Regulation applies to all substances, as mixtures or in articles, as well as substances to be released from products.

The following product types are out of scope of Turkey REACH:

  • Cosmetic products
  • Food and feeds
  • Goods, mixtures or articles in transit and goods in free-zone for re-export
  • Medical devices and medicinal products
  • Non-isolated intermediates
  • Radioactive substances and mixtures
  • Substances manufactured or imported for defense purpose
  • Transport of dangerous substances and mixtures by various modes
  • Veterinary products

INDUSTRY CONCERNS

The development of Turkey KKDIK is being viewed as part of a series of political steps designed to harmonize the country’s regulations with that of the EU ahead of any future union discussions. Nonetheless, industry actors at the ground level have expressed concern over the country’s ability to put the right infrastructure in place before the regulation is rolled out. A point of particular concern is the stipulation that only ‘authorized persons’ can sign off on registrations and notifications. This person must have logged 64 hours of face-to-face training before being accredited by designated bodies and must have an undergraduate degree in a relevant science subject. Many are worried about whether a sufficient pool of qualified experts actually exists.

Turkish companies have also raised questions about their data obligations under KKDIK and whether they will need to pay fees to access European data. This is important given the effective functioning of this regulation will require the exchange of substance information across borders.

Data Collection & Management

As with its European counterpart, the Turkish KKDIK Regulation requires companies to survey their supply chains for substance-related data and communicate the information collected to those further down the supply chain where applicable. This requires organized data collection methods that prioritize accuracy, organization and strong supplier relationships above all.

Compliance partners like Assent can take the hassle out of compliance with restricted substance regulations. The Assent Compliance Platform helps you track and manage your supply chain communications and data using one centralized software tool. With the support of a dedicated supplier engagement team to collect, analyze and organize the substance information in your supply chain, along with a team of regulatory experts to ensure you remain up-to-date on legal requirements, your Turkish KKDIK and/or EU REACH compliance programs will be ready to see success.

Contact us at info@assentcompliance.com with any questions or comments about how our industry-leading software can take the complexity out of your restricted substances compliance program.

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