Turkey finished drafting regulations for REACH implementation and has announced information about the process and critical dates. Turkey began the official process of implementing EU REACH into local regulations in 2011 and has now finished drafting regulations for REACH implementation. The draft regulation is named KKDIK an acronym which corresponds to the first letters of REACH written in Turkish.
Turkey’s Ministry of Environment and Urbanization (MoEU) is designated as the competent authority for REACH implementation and enforcement. In June 2014, MoEU organized a meeting with industry associates and discussed the details of the draft chemical control regulation. The draft has been published on the website of Chemical Management Department of MoEU and details some of the critical dates and requirements of Turkey’s REACH implementation.
According to the draft, the given registration window is from Dec 31st 2015 to Dec 31st 2018 for substances imported or manufactured before Dec 31st 2018. It should be noted that Dec 31st 2018 is Turkey REACH’S only registration deadline, and this deadline is mandatory for substances above 1 ton per year irrespective of tonnage band or substance classification. This is the major difference between Turkey REACH and EU REACH. As such industry should prepare for data submission for all tonnage bandings and chemical substance classifications before this deadline.
Companies that are exporting chemicals and articles containing certain chemicals can appoint an OR to act as their registration representative. However, there hasn’t been any definitive statement on how data compiled for REACH dossiers can be used for Turkish KKDIK. Another pending issue yet to be detailed in the KKDIK draft pertains to chemical risk assessment. MoEU will set criteria for training and certification of risk assessors. If it turns out that data generated for EU REACH can be used for Turkish KKDIK, companies will still need a Turkish certified risk assessor to complete some local assessment work. However, risk assessment requirements have not been detailed in this draft of Turkey’s KKDIK yet.
