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As the KKDIK registration deadline (regardless of tonnage) of December 31, 2023 approaches, the Minister of Environment, Urbanisation and Climate Change(MoEUCC) is in discussions regarding a possible extension based on tonnage bands.
Although no official statement has been issued, Ms. Ahu Çekim, an official from the MoEUCC, mentioned during the ChemCon Europe conference on October 26 that the registration deadline will be extended and new timeline for registration will soon be announced.
Ms. Ahu Çekim highlighted that the current number of registrations is lower than expected, which may be attributed to various factors such as the high cost of data, reluctance to take on the role of lead registrant, and the limited establishment of consortia. The industry has requested a re-evaluation of the registration deadline and a postponement based on tonnage bands. The proposed timeline aims to address the concerns raised by industry stakeholders.
The By-Law on Registration Evaluation Authorization and Restriction of Chemicals (KKDIK) was published in 2017 modelled on EU REACH. Although the main text is mostly the same, it consists some differences, including:
Information requirements are almost the same, while nanomaterials not included.
Some substances in the restricted list have not been harmonized yet.
There is no gradual registration based on tonnage.
Additional annex regarding chemical assessment expert.
According to Ms. Ahu Cekim, ongoing efforts are being made to align the restricted list Annex XVII in KKDIK with EU REACH. While the annex numbers in KKDIK correspond to those in EU REACH, KKDIK has an additional Annex XVIII that indicates criteria for chemical assessment experts. With this annex the MoEUCC aims to achieve more accurate and reliable dossiers by requiring registrations to be reviewed by a certified chemical assessment expert.
KKDIK follows a dossier submission process similar to that of the EU, and the Chemical Registration System (KKS) is compatible with IUCLID 6.4. It also integrates the Chemical Safety Assessment and Reporting System (KGDRS) to facilitate the preparation of Chemical Safety Reports (CSRs) in the system.
Evaluation under KKDIK focuses on three areas:
Compliance check of the dossiers submitted by registrants for each tonnage band, covering no lower than 5% of the total received registration.
Examination of testing proposals or downstream user report for a substance.
Priority substance evaluation on a risk-based approach.
Regarding the change of the Only Representative (OR) under KKDIK, Ms. Ahu Çekim confirmed that it is possible. The new OR must submit a letter to the Ministry explaining the need for the change and requesting the transfer of the old OR’s account including all the notifications and registrations to the new OR. This letter should be accompanied by two additional letters: One from the old OR acknowledging awareness of the situation, and the other from the company outside Turkey making this request. All letters must be signed and stamped.
