DETAILS ON C&L NOTIFICATIONS AND FAQ ON TURKISH SEA REGULATION

Content addition date : 22-09-2014

Turkish implementation of CLP has been published on the date 11th December 2013 on the Official Journal with the number 28848 and came into force on the date of publication. Turkish CLP which we can call with its Turkish abbreviation as SEA also has transition periods for its obligations to apply, as it was in the EU-CLP (1272/2008 EC) for the new classification principles to be applied for substances and mixtures. Also, it will be fully repealing the former Turkish classification regulation as of date 1st of June 2016.

We can briefly summarize the obligations of chemical manufacturers and importers as below;
* Notification to the Turkish C&L inventory for which the notification period will start by 1st of June 2014 and will be ending as of 1st of June 2015 for the substances that have been placed on the market, either on their own or in a mixture, before 1st of June 2015.

* Substances that are placed on the market after 1st of June 2015, needs to be notified to the Turkish C&L inventory within a month from the day of the first date of import or manufacturing.

* Classification & Labelling according to the new regulation for substances will be obligatory as of 1st of June 2015 and for mixtures the CLP Classification & Labelling criteria obligation will apply as of 1st of June 2016. As a general principle and similar to EU CLP, a two-year transition period for the products that were placed on the market prior to that date, will apply to prevent a requirement for re-labelling.

One of the unique point in the Turkish CLP implementation is, as defined in article 41 of the regulation, without any prejudice to the primary obligation belonging to the importer, chemical exporters to Turkey may cover the C&L notification obligation of their importers through their appointed Legal Representatives who are appointed by exporter companies that export to Turkey. This option was intentionally added to the legal text after the initial draft of the SEA regulation to prevent the CBI issues of Chemical industry who exports to Turkey.