Pre-registration for KKDIK, Turkey’s new REACH regulation, should be completed by the end of 2020.
In June 2017, the Government of Turkey published in the Official Gazette the Registration, Evaluation, Authorization, and Restriction of Chemicals regulation, also called KKDIK, which is the Turkish abbreviation of REACH. The Ministry of Environment and Urbanization (MoEU) is the responsible body for enforcement and implementation of KKDIK.
The regulation requires companies importing into or manufacturing in Turkey to register all chemical substances whether pure or in mixture with an annual production or importation volume of more than one ton. The KKDIK regulation includes foreign chemical exporters to Turkey as well as Turkish exporters who use chemicals in their formulations and/or products, with some exceptions. KKDIK is very similar to the EU REACH regulation, with some differences. For example, KKDIK does not separate pre-registration and registration deadlines depending on the classification of the substance or the annual tonnage band and the Chemical Safety Report that is to be submitted during the registration period should be prepared and signed by a local Certified Chemical Safety Expert.
Exporters of chemical products to Turkey can register their products in Turkish through their subsidiary, distributor, or appointed representative (“only representative”) to fulfill KKDIK obligations. This regulation is expected to come into force in January 2021. It is possible to pre-register chemical substances until December 31, 2020. All chemical substances should be registered by December 2023. After December 31, 2023, chemical substances, both pure and in mixtures or in articles that are equal to, or above, one metric ton per year, cannot be manufactured or placed on the market if they are not registered in accordance with the relevant KKDIK provisions.
The Turkish Chemical Manufacturers Association recommend that companies register in the pre-registration phase. Pre-registration will enable the regulators as well as other manufacturers and importers to see the list of companies that will register the same product in the system. Companies that pre-register the same product can contact each other and share the registration fee. Registration fees have not been published but are expected to be announced at the end of 2020. Registrations will be done through MoEU’s Chemical Registration System found in the e-Government Gateway system. This system is called “e-devlet” (https://www.turkiye.gov.tr/ecbs-25). The e-Government Gateway is a website offering access to all public services from a single point. Once companies enter their contact and product details, they will be added into the system.
Other guidance documents (in Turkish)
For more information, please contact;
U.S. Commercial Service Turkey