The official registration deadline at the end of 2023! Turkey Chemical Registration KKDIK Important Update

Release time:

2023-05-26 10:28

Recently, the Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) issued new implementation guidelines in accordance with the KKDIK Regulation on the Registration of Chemicals in Turkey. Under the new guidelines, it is not mandatory to provide importer information when registering substances. Chemical Safety Reports (CSR) can also be submitted in English, with additional time to submit Turkish translations after the registration deadline. In addition, "Registrant Identity" and "Registration Number" may be classified as Commercial Information Confidential (CBI).

Regulatory background

Effective from 23 December 2017, KKDIK (short for Turkish Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals) is a chemical regulatory framework that requires the registration of chemicals produced or imported in Turkey in quantities greater than 1 ton/year. KKDIK follows the European Union (EU) Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation. Although substances are still allowed to be pre-registered, KKDIK has been in the registration phase since 2022 with a registration deadline of 31 December 2023. These substances are registered online through the KKS information technology platform, which is similar to the REACHIT and IUCLID platforms of the European Chemicals Management Agency (ECHA). Enterprises outside Turkey can entrust a sole representative (OR) in Turkey.

As of May 2023, the deadline for KKDIK registration has not changed: that is, all enterprises exporting more than 1 ton/year need to complete formal registration by December 31, 2023, otherwise they will not be allowed to continue to manufacture, import or sell the chemical within Turkey.

KKDIK Registration Requires New

01 Importer information is not provided

Previously, the law required that the registered entity is the sole representative (OR) and must provide information on at least one Turkish supplier. The industry has repeatedly expressed concern about this requirement, which increases the burden on registered businesses. Under the new regulations, the competent authorities recommend that the sole representative collect information on Turkish importers as much as possible, but no longer make it a mandatory field in the declaration system. However, the OR must maintain an up-to-date list of importers, the tonnage covered by each importer, and the latest Safety Technical Specification (SDS) information.

New Anrun Interpretation: This gives a sigh of relief to enterprises that have identified importers and will increase the willingness of potential registered companies.

02 Chemical Safety Report (CSR) can be provided in English first

According to the previous registration requirements, the registration of chemical substances above 10t/a must provide a Chemical Safety Report (CSR) in the Turkish language. For many businesses, this requirement significantly delays the registration process, and many English registration files need to be translated into Turkish. As the registration deadline approached, the competent authority made a concession and allowed the submission of the CSR report in English before the deadline, but the report in Turkish must be submitted to the official within 1 year after the deadline of December 31, 2023.

New Anrun Interpretation: The current regulations stipulate that all tonnage segments have only a fixed and strict registration period, coupled with the requirement to translate into Turkish, which has become an important obstacle to KKDIK registration. CSR usually has a large number of pages, and translation of complex science requires technical expertise and proficiency in Turkish. Allowing an extra year should increase the number of potential customer registration submissions.

03 CBI Update

Registrants or their ORs can now also apply for "Registrant Identity" and "Registration Number" to be listed as CBI (Business Information Confidentiality) in the KKSIT system, which was not allowed under the previous regulations. The CBI must be validated according to the template in the KKS. For files that have already been submitted, companies that require CBI must initiate the KKDIK registration file update process. CBI applications are subject to payment.

New Angrun Interpretation: Not long ago, technical experts in Turkey urged further adjustments to KKS to include confidential areas commonly found in EU tools. It took months for Turkish officials to issue new guidance. With the deadline rapidly approaching, only 25% of potential customers are expected to register, and failure to complete KKDIK registration by the deadline could lead to supply chain disruption. In addition, supply chain disruptions and adverse economic impacts are likely to continue as the Turkish government has previously dealt with the effects of several tragic earthquakes and upcoming elections.

New Anrun Consulting provides relevant registration services for enterprises that need to register KKDIK for Turkish chemicals. Please contact us for details.

(Publicized) Record of Environmental Management of New Chemical Substances in the First Half of 2023

Notice on Soliciting Comments on the National Eco-environmental Standard "Code for Nomenclature of Environmental Management of Chemical Substances (Draft)"

(Publicized) Record of Environmental Management of New Chemical Substances in the First Half of 2023

Notice on Soliciting Comments on the National Eco-environmental Standard "Code for Nomenclature of Environmental Management of Chemical Substances (Draft)"

Latest developments

Key Illustration of Railway Transportation Regulations for Consumer Lithium Battery Cargo

Recently, the Ministry of Industry and Information Technology of the National Railway Administration China National Railway Group Co., Ltd. announced the guidance on the railway transportation of consumer lithium battery goods. For details, please refer to our public article. Official

Answers to Frequently Asked Questions about the Environmental Management Measures for New Chemical Substances (Order No.7)

I recommend: For pre-registration projects with large tonnage and short grace period, or small tonnage pre-registration projects that are clearly registered in the future, it is recommended to choose joint registration and join the joint registration IT system agreement this time. For pre-registration projects that are clearly not registered in the future, it is recommended to choose subsequent registration. May I ask you

Cancellation of GMP certification means stricter supervision of drug production?

The cumbersome process of GMP and GSP certification has made many pharmaceutical manufacturers and distribution companies feel the strict supervision of the pharmaceutical industry. On September 25, 2019, the State Food and Drug Administration issued a notice on the study, publicity and implementation of the the People's Republic of China Drug Administration Law., It is clearly proposed to strengthen dynamic supervision and cancel the drug production quality management practice (GMP) certification and the drug business quality management practice (GSP) certification.

Dry goods! Common technical questions and answers on new raw materials for cosmetics