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KKDIK Regulation (Turkish Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals)
"Registration, Evaluation, Authorization and Restriction of Chemicals” (KKDIK) was published by Turkey's Ministry of Environment, Urbanization and Climate Change 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.
On December 23, 2023, Regulation Nr. 32408 on amending the KKDIK Regulation was published. According to this regulation, registration deadlines has been postponed according to the tonnage band and hazard categories of substances, these are detailed on the important dates indicated below.
Registration, Restriction and Authorization are parallel processes within the scope of KKDIK.
Registration within the scope of KKDIK is realized in two steps respectively; Pre-Registration Process and Registration Process. EU REACH registration will not be applicable in Turkey for substances to be registered under KKDIK. Therefore, these substances should be registered within the scope of KKDIK.
Pre-Registration Process, which is the first step, entered into force on 23 December 2017 and will continue until the period specified in the procedures and principles to be published by the Ministry. Registration Process entered into force after the completion of the initial 3-year period for pre-registration.
We can summarize important dates for these processes as follows;
23 December 2017: Pre-Registration provisions entered into force for the substances which falls in the scope of KKDIK.
01 January 2021- After: The Registration Process started 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;
Restriction Provisions entered into forced on the date 23 December 2017. Currently, all Restriction Provisions indicated in Annex 17 of KKDIK Regulation are active.
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 Provision
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.
Regulation Nr. 32408 on Amending the Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals (KKDIK)
ARTICLE 6 -The phrase "until 31/12/2020" in the provisional Article 1 of the same Regulation (KKDIK Regulation) has been amended as "until the periods specified in the procedures and principles to be published by the Ministry".
As stated in KKDIK Regulation, it is obligatory to submit Pre-SIEF (Pre-Registration) for chemical substances with registration obligation under the scope of KKDIK. This obligation came into force as of December 23, 2017.
There is a Pre-Registration / Registration obligation for substances manufactured or imported in 1 ton or more per year in their own form, in mixtures or in an article.
All actors, who will register the substances, also will submit a Pre-SIEF which will contain the following information through Chemical Registration System (or KKS tool) under Integrated Environmental Information System of the Ministry;
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 summarized form of the substances exempted from registration by KKDIK. It should be noted that there are some details about these exemptions.
Substances 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 at 1 ton or more.
Substances which are out of Scope for KKDIK are: Since the substances in this group are not covered by KKDIK, they do not have Registration or Pre-Registration obligations.
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.
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.
As CHEMLEG, Our Services within the scope of KKDIK include;
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