By-Law on Registration, Evaluation, Authorization and Restriction of Chemicals (Turkish REACH) (abbreviation of KKDIK as Turkish)
"Registration, Evaluation, Permission and Restriction of Chemicals” was published by the Turkey's Ministry of Environment and Urbanization on June 23, 2017 in the Official Gazette No. 30105. KKDIK entered into force on December 23, 2017. KKDIK has been prepared on the basis of REACH Regulation (EC) No:1907/2006 dated 18/12/2006 and adapted to the Turkish Industry within the frame of compliance with the legislation of the European Union.
Registration, Restriction and Permission are parallel processes within the scope of KKDIK.
Registration within the scope of KKDIK will be realized in two steps respectively; Pre-Registration Process and Registration Process. EU REACH registration of the substances will not be applicable in Turkey. So, these substances should be registered within the scope of KKDIK.
Pre-Registration Process, which is the first step, will be realized between the dates 23 December 2017 and 31 December 2020. After the Pre-Registration Process is completed on the date 31 December 2020, the Registration Process will start.
We can summarize important dates for these processes as follows;
23 December 2017- 31 December 2020: Pre-Registration will be realized for the substances which are evaluated within the scope of KKDIK.
01 January 2021- After: The Registration Process will start for the substances which are evaluated within the scope of KKDIK. However, there are important dates that need to be mentioned for this period. These dates and their importance are as follows;
01 January 2021- 31 December 2023: The Registration Process will be started for the substances that are evaluated within the scope of KKDIK. However, the Pre-Registered substances can be manufactured or imported between these dates while their Registration Process continue. The substances, which are not Pre-Registered, can be manufactured or imported in condition of completion of the Registration.
01 January 2024 and After: The substances, which are within the scope of KKDIK, can be manufactured or imported in condition of completion of the Registration as of 01 January 2024.
Restriction Provisions is entered into forced on the date 23 December 2017. The other provisions will be active gradually as of this date. Also, all the Restriction Provisions will be active on December 31, 2023.
REGISTRATION PROCESS of KKDIK
Pre-Registration (Pre-SIEF) and Registration within the scope of KKDIK
The process which is defined as Pre-Registration Process on REACH to prepare for the Registration Process, is called Pre-Substance Information Exchange Forum (pre-SIEF) in the KKDIK Regulation.
Some of the relevant Articles for Pre-Registration, that are mentioned as Pre-Substance Information Exchange Forum (pre-SIEF) in the KKDIK Regulation, are specified as follows;
TRANSITIONAL ARTICLE 1- (1) All registrants, shall send a pre-SIEF including below mentioned information to the Ministry through Chemicals Registration System in the website of Ministry until 31/12/2020:
a) substance identity according to Annex-6;
b) Role in the supply chain
Entry into Force
ARTICLE 66- (1) ç) All other provisions will enter into force 6 months later the date of its publication on the Official Gazette.
As stated in the Regulation, it is obligatory to submit Pre-SIEF (Pre-Registration) for chemical substances with registration obligation under the scope of KKDIK. This obligation comes into force as of December 23, 2017. The deadline for submission of the Pre-SIEF to the Ministry's assessment is 31 December 2020.
There is a Pre-Registration / Registration obligation for substances manufactured or imported in 1 ton or more per year in its own form or in the mixture.
All actors, who will register the substances, also should submit Pre-SIEF which will contain the following information through Environmental Information System (or KKS tool) of the Ministry before 31/12/2020;
a) Substance identity according to Annex-6;
b) Role in the supply chain
Substances Which Are Exempted from The Registration Provisions Under The KKDIK
The substances in the groups listed below are the most abstract form of the substances exempted from registration by KKDIK. It should be noted that there are some details about these exemptions.
Groups not included in the following lists are obliged to fulfill their Registration and Pre-Registration obligations under the KKDIK in case they are imported or manufactured 1 ton or more.
The Substances, which are out of Scope for KKDIK: Since the substances in this group are not covered by KKDIK, they do not have Registration or Pre-Registration obligations.
Radioactive substances and mixtures,Substances subject to customs supervision on their own or in a mixture or in an article (provided that they do not undergo any treatment or processing, and which are in temporary storage, or in a free zone or free warehouse with a view to re- exportation, or in transit),Non-isolated intermediates, Wastes (evaluated Bylaw on Waste Management and Radioactive Waste Management),Substances and mixtures which are manufactured or imported for the purpose of defense, Substance in the form of transport (by rail, road, inland waterway, sea or air).
The Substances, which are out of Scope for Registration Process of KKDIK: The substances in this group are exempted from Registration and Pre-Registration obligations, even though they are covered by the KKDIK Regulation.
Food and feeding stuffs, Medicinal products (both for Human Use and Veterinary), KKDIK ANNEX-4 substances, KKDIK ANNEX-5 substances, Substances (on their own or in mixtures or in articles) which have been registered previously and which are recovered, Re-imported substance which is the same with the exported substance that have been registered previously, Polymers
Substances Regarded as Being Registered: The active ingredients of the following product groups are considered to be registered under the KKDIK. For this reason, they do not need to be registered.
Biocidal Product Active Substance, Plant Protection Product Active Substance
As CHEMLEG, Our Services Relevant of Pre-Registration within the scope of KKDIK (Turkish REACH);
Acting as an Only Representative for all process of KKDIK
Submission of Pre-Registration (Pre-SIEF) dossier on behalf of you by providing Only Representative Service
Compiling substance-based inventory for your products imported to Turkey,
Management of Pre-Registration Process for the substances evaluated within the scope of KKDIK
Conducting Inventory for the substances under Annex 17 (Restricted Substance List)
Conducting Inventory for the substances having Pre-Registration obligation.