KKDİK Regulation (Turkish REACH) Compliance Services

Compliance to KKDIK (Turkish REACH Regulation) (O.G. – 30105 – 23 June 2017)

KKDIK Regulation is the Turkish REACH implementation. The process and implementation is quite similar with the EU REACH Regulation, but for sure there are some nuances. Regulation was published on the date 23 June 2017.
The scope of this regulation covers all substances above 1 mta that are either manufactured locally or being imported in to Turkey either on their own or within a mixture.

Also the substances that are exempt from the EU REACH Regulation (due to Annex IV & Annex V) are as well exempt from KKDIK too.

The critical points are in this regulation:

• The pre-registration process of substances started on 23.12.2017. It is stated that the details and provisions regarding the expiration date will be published later by the Competent Authority.
• The registration process started on 01.01.2021, and the dates it will end depending on the tonnage amount and substance hazard are listed below.

I. Registrations should be completed until 31/12/2026 for substances that meet the following conditions. 

• a) Substances manufactured or imported on their own or in mixtures or in articles, in quantities of 1000 tons or more per year.
• b) Substances manufactured or imported on their own or in mixtures or in articles, in quantities of 100 tons or more per year and classified as Aquatic Acute 1 and/or Aquatic Chronic 1 (H400, H410). 
• c) Substances manufactured or imported on their own or in mixtures in quantities, or in articles of 1 ton or more per year and classified as carcinogenic, mutagenic and toxic to the reproductive system, Category 1A and 1B. 

II. Until 31/12/2028 for substances manufactured or imported in quantities of 100 tons or more annually, either on their own or in mixtures or in articles. 

III. Until 31/12/2030 for substances manufactured or imported in quantities of 1 ton or more per year, on their own or in mixtures or in articles.

The polymers are exempt from registration. But the monomers used for manufacturing the polymers have to be registered with the same definition and same provisions of EU REACH Regulations

As the pre-registrations/registrations to the KKDIK can only be submitted by Turkish Legal entities, companies that are exporting chemicals to Turkey can appoint an OR in order to support their importers in Turkey to comply with this regulation and to keep their CBI safe.

Exemptions from the scope of that regulation are listed under the annexes to the regulation and can be summarised as: 

• Substances with an annual average below 1 mta. 
• Substances that are covered by Annex IV & V of EU REACH. 
• Substances in transit provided that they don’t undergo a process. 
• Polymers (but not the monomers used for manufacturing the polymers).

CRAD provides the below listed services for your company and your importers to comply with KKDIK:

• OR Service 
• Scope identification 
• Pre-registration & Registration of substances 
• Translation of the Robust Study Reports, CSR, Chemical Safety assessment reports in to Turkish 
• Services to be covered by a Certified Chemical Safety Assessment Experts
• Compilation of SDS & e-SDS compliant to KKDİK 
• General and company specific Regulatory training
• Third Party Representative Services and/or acting as a Trustee. 
• Outsourced support to the Regulatory teams of companies.