On 23 June 2017, the Ministry of Environment and Urbanization (MoEU) in Turkey published its REACH-like KKDIK regulation. The KKDIK regulation will come into force on 23 Dec 2017. "KKDIK" are the first letters of REACH written in Turkish. Like EU REACH regulation, the KKDIK regulation requires companies to register all substances manufactured in Turkey or imported into Turkey with volume above 1t/y before a given deadline.

1. ※ Pre-registration deadline: 31 Dec 2020.

2. ※ Registration deadline: 31 Dec 2023.

KKDIK will bring various Turkish chemicals legislation under one law. It will replace three existing laws:

1. ※ Regulation on the Inventory and Control of Chemicals;

2. ※ Regulation on the Preparation and Distribution of Safety Datasheets for Hazardous Materials and Products; and

3. ※ Regulation on the Restrictions Relating to the Production, Supply to the Market and Use of Certain Hazardous Materials, Products and Goods.

Scope of KKDIK Regulation (Turkey REACH)

KKDIK applies to all chemical substances on their own or in preparations as well as in articles. However, the regulation does not cover the following substances and mixtures.

1. 1. Radioactive substances and mixtures;

2. 2. Goods, mixtures or articles in transit and goods in free-zone for re-export;

3. 3. Non-isolated intermediates;

4. 4. Transport of dangerous substances and mixtures by various modes;

5. 5. Substances manufactured or imported for defense purpose;

6. 6. Medicinal products;

7. 7. Veterinary products;

8. 8. Medical devices;

9. 9. Cosmetic products;

10. 10. Food and feeds;

     

Industry's Obligations under KKDIK

Key differences between Turkey KKDIK and EU REACH

Although KKDIK is almost a copy-paste of the EU REACH Regulation, there are unavoidably few differences between Turkey KKDIK and the EU REACH. The striking difference as follow:

1. ※ KKDIK pre-registration tonnage band will not trigger the deadline for registration. Registration period or the deadline for registration will be the same for all substances pre-registered and a 3 years time frame is envisaged for the registration period.

    

2. ※ KKDIK requires Chemical Safety Report should be prepared and signed by a local Certified Risk Assessor. Similar requirements are in place under the SDS Regulation of Turkey.

    

3. ※ SDSs have to be prepared in Turkish and signed by a certified Turkish expert.  

BACL Testing:

To comply with KKDIK regulation, companies mainly need to do the followings:

1. ※ Pre-register/register applicable substances >=1t/y before given deadline. If your company is based outside of Turkey, you may need to appoint a local only representative.

2. ※ Ensure that your safety data sheets are compliant.

3. ※ Monitor the list of substances subject to authorization on annex 14 and the list of restricted substances on annex 17.

BACL Service:

BACL, headquartered in the United Sates, is a global comprehensive international third-party testing and certification service organization. With knowledge of the laws and regulations of various market, BACL can not only offer testing and certification services for finished products including domestic appliance, textile and garment, shoes and toys, but also help companies to execute quality control over the whole industry chain from raw material to finished products.