Turkey REACH and its Implications

Turkey REACH law is like EU REACH and requires the companies to pre-register (by 31 Dec 2020) and register (31 Dec 2023) substances (on their own, in mixtures or in articles) manufactured in Turkey or imported into Turkey with volumes equal to or above 1 ton per year. This is called as KKDIK. KKDIK stands for Turkish for Registration, Evaluation, Authorization and Restriction of Chemicals.

Only one representative (OR) can be appointed by companies to submit KKDIK registration and CLP notification on their behalf.

There are no separate deadlines set depending on the classification of the substance or the annual tonnage band, for pre-registration and registration.

• Submissions for Pre-MBDF will be accepted after 31 Dec 2020
• All registrations must be completed between 31 Dec 2020 – 31 Dec 2023

After 31st Dec 2023,substances that are equal to or above one ton per annum, cannot be place or manufactured in Turkish market, If they are not registered as per KKDIK provisions. KKDIK came into force on 23rd Dec 2017 and replace below 3 regulations in Turkey.

• The Inventory and Control of Chemical Regulation (KEK) – Effective from 23, Jun 2017
• Regulation on Restrictions for the Manufacture, Marketing and Use of certain Dangerous Substances and preparation – Effective from 23 December, 2017.
• Regulation on Safety Data Sheets for Hazardous Substances and Mixtures (GBF)- Effective from 31 December, 2023.

Below are the main obligations that is under KKIDK:

• Notification on MBDF- Deadline is 31 Dec 2020
• Registration – Deadline is 31 Dec 2023
• Authorization – Date/substance in Annex XIV determined by the MoEU (Turkish Ministry of Environment and Urbanization)
• Restriction – Dates Annex XVII (Article 66 of KKDIK regulation)

Below substances and Mixtures are not covered by KKDIK:

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

Active substances and co-formulants that are only manufactured or imported for using in plant protection products need to be registered under Turkey REACH. Active substances approved for biocidal products also need to be registered. GHS safety data sheet and labelling are still needed for the plant protection products and biocidal products, that are exempt from KKDIK.

Candidate list for Turkey REACH is same as that of EU candidate list.

The main key difference between EU REACH and Turkey REACH is that, KKDIK, requires only trained and qualified experts sign off and registrations and notifications. There are no other major differences between EU REACH and Turkey REACH.