KKDIK (Turkey REACH)
What is KKDIK?
On June 23rd, 2017, the Ministry of Environment, Urbanisation and Climate Change (MoEUCC) of Turkey published its KKDIK regulation which is very similar to EU REACH regulation, aiming to regulate the safe use of chemicals in the Turkey market to ensure sound protection for human health and the environment. KKDIK is an acronym in Turkish for Registration, Evaluation, Authorization and Restriction of Chemicals.
The KKDIK regulation came into force on December 23rd, 2017. It replaces the following three existing laws:
• Regulation on the Inventory and Control of Chemicals, No.27092 (starting from June 23rd, 2017),
• Regulation on the Restrictions Relating to the Production, Supply to the Market and Use of Certain Hazardous Materials, Products and Goods, No.27092 (starting from December 23rd, 2017).
• Regulation on the Preparation and Distribution of Safety Datasheets for Hazardous Materials and Products, No.29204 (starting from December 31st, 2023)
Regulatory Scope
Similar to EU REACH regulation, chemical substances on their own or in mixtures or intended to release in articles, manufactured in or imported to Turkey in quantities equal to or more than 1 tonne a year must be registered with the MoEUCC. Additionally, companies should fulfill obligations of Evaluation, Authorization and Restriction and safety data sheet (SDS) as well.
Exemptions
Being exempted from KKDIK Regulation
• Radioactive substances
• Substances subject to customs supervision
• Substances for use in national defense
• Wastes
• Non-isolated intermediates
• Carriage of hazardous substances by rail, road, inlandwaterway, sea or air
Being deemed as registered substance
• Active substances for use in Biocidal Products
• Active substances for use in Plant Protection Products
Being exempted from registration
• Foods or feeding stuffs
• Medicinal products
• Substances included in Annex IV
• Substances included in Annex V
• Registered substances from the recovery process
• Registered substances being re-imported
• Polymers (monomers and other reactants need to be registered)
• PPORD substances (PPORD notification)
Registration
KKDIK registration includes two stages, namely Pre-SIEF (Pre-registration) and Registration.
Pre-registrations and Registrations are submitted online through the KKS tool. All pre-registrations should be submitted before December 31st, 2020 in principle, while pre-registration is still open for now which depends on MoECC’s announcement later on.
The registration deadline for substances manufactured in or imported into Turkey is as follows:
December 31, 2026
- for the substances ≥ 1.000 tpa;
- for the substances ≥100 tpa which are classified as aquatic acute1/chronic1;
- for the substances ≥1 tpa which are classified as CMR Category 1A/1B.
December 31, 2028
- For the substances≥ 100 tpa
December 31, 2030
- For the substances 1 – 100 tpa
Registration Timeline
Key Points
• Only certified Chemical Assessment Experts described in KKDIK Annex XVIII can compile the dossier, CSR as well as SDS/eSDS.
• No distinction between phase-in and non-phase-in substances. Both existing and new substances could be pre-registered and registered.
• The registration deadline under KKDIK is related to tonnage band and substances’ classification.
• Data required for registration are exactly the same as those required in EU REACH(Annex VII/VIII/IX/X).
• EU REACH data is acceptable for KKDIK registration, but new usage right is required.
Other Obligations under KKDIK
|
Evaluation |
• Authority: proposed by MoEUCC
• Duties: Dossier evaluation and substance evaluation • Results: Decision on whether to require more information and evaluation; substance may be included in authorization or restriction list |
|
Authorization |
• Candidate list of Authorization: SVHC
• Authorization List: Annex XIV • Results: Substances included in Annex XIV cannot be manufactured, imported or used unless any authorization has been granted |
|
Restriction |
• Restriction List: Annex XVII
• Results: Must comply with restrictions for substances stated in Annex XVII • Provides effective dates for entries of restrictions |
Related Turkish Regulations and Obligations
| SDS Regulation | SEA (CLP) Regulation |
| SDS regulation (No.29204) is to be replaced by KKDIK Annex II on December 31st, 2023. Between December 23rd, 2017 and December 31st, 2023, both of the two regulations are in force.
Key Requirements： • Standard 16-section SDS • Must be prepared in Turkish • Should be prepared and signed by a certified expert in Turkey • A copy of SDS should be submitted to MoEUCC |
C&L (Classification & Labelling) Notification
For substances which are classified as hazardous ones, manufacturers or importers have to submit C&L Notification to the Turkish competent authority to form the C&L inventory • Non-Turkish manufacturers can appoint an OR to complete the C&L Notification • For substances placed on the market after June 1st, 2015, the competent authority should be notified at least within one month after such substances are placed on the Turkish market for the first time • Submit through KKS tool |
Relevant Links
- Turkey REACH Registration Deadline Nears – Act Now to Ensure Compliance
- Free Webinar | Turkey REACH: Understanding KKDIK Registration & Updates
Our Services
• Only Representative Service
• Pre-registration Service
• KKDIK Registration Service
• SIEF Management
• Testing Supervision
• Safety Data Sheet (SDS) and Label Preparation
• C&L Notification
• KKDIK Compliance Analysis
• Consortium Supporting Service
