TURKISH REACH NOW HAS A NAME: KKDIK IS GETTING CLOSER…

Content addition date : 05-08-2014

Turkey started their process to implement EU REACH into local regulations via Project started in 2011. The Project ended as of 2013 with the draft of the regulation as an output of the REACH implementation Project.

Previous regulation on Chemical Control in Turkey named as Chemical Inventory and Control Regulation (CICR 27092) was frequently named as Turkish REACH, however it was indeed implementation of 793/93 EEC. Now we better understand that naming CICR as Turkish REACH was not quite correct. Thus I guess we need to name the new regulation as Real Turkish REACH.

As of June 2014 MoEU of Turkish Republic who is the Competent Authority for REACH implementation and Enforcement had organised an initial meeting with the industry associations as the Stakeholders of the regulation. Regulation is named as KKDIK which corresponds to the first letters of REACH written in Turkish. Initial draft of the regulation is published on the website of Chemical Management Department of the MoEU. The draft regulation gives some clues about the implementation process as well as the critical dates about the implementation.

The term for registrations is given as from 31.12.2015 to 31.12.2018 for the substances imported or manufactured before 31.12.2018.

As you would realise there is no separation of deadlines depending on the tonnage bands or the classification of the substances. That was as well a point which EU REACH was criticised due to creating ambiguity for the SIEF’s to identify the cost sharing principles due to the ambiguity about making a forecast for future participants for lower tonnage bands. We will now have the opportunity to compare both approach.

The registration deadline given on the draft KKDIK regulation shows us that Turkish competent authority prefers a registration deadline for all substances that is even later than the last registration deadline for EU REACH. Thus dossiers of all substances even at the lowest thresholds will be ready for submission before that date.

For sure SIEF’s established under the scope of REACH needs to consider how to make an arrangement to the SIEF agreements in order to be able to use the data compiled for REACH dossiers to be used for TR KKDIK too. We are sure that there will be lots of discussion on this data sharing principles and we will see how it is going to be solved by time.

Companies that are exporting chemicals ( and articles that are containing some certain chemicals can appoint an OR and submit the registrations through the OR by which then their importers will become downstream users.

Also the competent authority wishes to increase the capacity on chemical risk assessment and inserted an Annex XVIII to the TR KKDIK which mentions the criteria for training and certification of a Risk Assessor. This annex makes us feel that even though the data sourced from REACH registration dossiers are used for TR KKDIK registrations, companies will need a Turkish certified risk assessor and a work load due to the translations of the data and other assessment reports by these assessors.

 Please click here for the KKDIK draft Regulation...