Turkey Regulatory News

The Turkish Ministry of Environment, Urbanization, and Climate Change, and the Union of Chambers and Commodity Exchange (TOBB) have met with the key companies from the industry to discuss the future o...

The Turkish Ministry of Environment, Urbanization, and Climate Change, and the Union of Chambers and Commodity Exchange (TOBB) have met with the key companies from the industry to discuss the future of KKDIK and the implementation of the updates that were published in December 2023. The outcome of the privately held meeting is reportedly a draft of the long-awaited circular on procedures and principles.

Draft Circular in the Works

According to the draft, new deadlines for late pre-registrations (LPRs) may be proposed, and new rules would be set for the election of the lead registrant (LR) as well data sharing, two issues on which the Ministry has already received considerable feedback from the industry in public meetings. New rules are expected to set clear boundaries and steps for the election mechanism as well as joint submission.

Work Groups to Improve Support

It is also proposed that new work groups will be formed to put into practise the collaboration between TOBB and the Ministry, as proposed in the 2023 regulation updates. These work groups will be expected to resolve ongoing disputes as well as answer questions to help registrants, something that was difficult for the Ministry to find the time and capacity to do over the past years. leading to much criticism of the Ministry.

The discussion is expected to continue throughout the month of November with a view to finalize the draft and eventually publish the circular before the end of the year.

  On February 12th, the Ministry of Environment, Urbanization, and Climate Change in Türkiye made an announcement regarding Safety Data Sheets from the Chemicals Help Desk. Key points from thi...

On February 12th, the Ministry of Environment, Urbanization, and Climate Change in Türkiye made an announcement regarding Safety Data Sheets from the Chemicals Help Desk.

Key points from this announcement:

• You can continue to use existing safety data sheets compliant with previous regulations unless there are changes in substance-related information or processes.
• Depending on the requests of your downstream-users, safety data sheets may need to be reviewed.
• Attention should be paid to ensuring that the classification in safety data sheets is similar to the classification in KKDIK registration files.
• All newly prepared safety data sheets must comply with the KKDIK regulation.
• If your existing safety data sheets are not compliant with previous regulations, they must be updated as soon as possible.
• If you have any doubts about the completeness of your safety data sheets in any of the above, reviewing them would be the best course of action.

The Revolving Fund Directorate of the Ministry of Environment, Urbanization, and Climate Change has disclosed the registration fees for KKDIK in 2024. Compared to 2023, the fees have increased by an a...

The Revolving Fund Directorate of the Ministry of Environment, Urbanization, and Climate Change has disclosed the registration fees for KKDIK in 2024. Compared to 2023, the fees have increased by an average of 44% and a maximum of 60% in TL.

Currently, registration fees range from 180 TL/€6 (for SME companies jointly registering 1-10 tonnage) to 43,000 TL/€1315 (for large companies individually registering 1000+ tonnage substances). The fees vary based on the tonnage band, company size, and whether it is a joint or individual submission. This underscores the importance of companies opting for joint registration.

If you haven't completed the pre-registration of your substances, please do so to be part of the Substance Information Exchange Forum (SIEF) and to engage in joint registration.

For more details on the 2024 KKDIK registration fees and updated deadlines under KKDIK, please contact GPC.

KKDIK, also known as Turkey REACH, was enacted on June 23, 2017, as part of the EU Adaptation policy. This regulation focuses on the registration, evaluation, authorization, and restriction of chemica...

KKDIK, also known as Turkey REACH, was enacted on June 23, 2017, as part of the EU Adaptation policy. This regulation focuses on the registration, evaluation, authorization, and restriction of chemicals to ensure the protection of human health and the environment.

Registration for KKDIK began on January 1, 2021, and the deadline for registration was set on December 31, 2023. However, on 23 December 2023, the Ministry of Environment, Urbanization and Climate Change of Türkiye announced an official postponement of the KKDIK deadline. The main objective of this announcement for KKDIK is to determine different deadlines for tonnage bands like how the UK is experiencing with UK REACH. 

Key points from this announcement:

• A new paragraph was added to Article 12 (joint submission of data by multiple registrants) giving responsibilities to TOBB (Union of Chambers & Commodity Exchange) regarding the election of lead registrants, data and cost-sharing, joint registration process by future procedures and principles to be published by the Ministry.

• Amends the beginning date in Article 24 (inquiry) and deadline in 25 (SIEF formation) of the regulation, extending them from "31/12/2023" to "31/12/2030."

• Extends the termination date of SIEFs to 31/12/2032 from 31/12/2025.

• Deadline for pre-registration to be removed and amended in a way that references timelines specified in procedures and principles to be published by the Ministry

• New transitional article for new separate deadlines

  • Substances above 1000 tons, substances above 100TPA that are Aquatic Acute 1 or Aquatic Chronic 1 (H400,H410), and substances above 1TPA that are CMR category 1A or 1B having the registration deadline of 31/12/2026

  • Substances above 100TPA have a deadline of registration by 31/12/2028

  • Substances above 1TPA have a deadline of registration by 31/12/2030

• Evaluation, inclusion in the authorization list, and creation of candidate substances list for authorization to begin by 31/12/2026

At GPC, we are always ready to act on your behalf for your compliance needs with our worldwide team of experts and professionals to ensure the safety of your trade in Türkiye.

Stay tuned for our webinar on the update, explaining each change in more detail and how it will affect the registration process.

KKDIK (aka Turkey REACH) came into force on 23 June 2017 as a result of the EU Adaptation policy. The regulation provides the means of registration, evaluation, authorization, and restriction of chem...

KKDIK (aka Turkey REACH) came into force on 23 June 2017 as a result of the EU Adaptation policy. The regulation provides the means of registration, evaluation, authorization, and restriction of chemicals and safeguarding human health and the environment. 

The KKDIK registration period started on 1 January 2021 and the registration deadline is 31 December 2023. On the other hand, the current number of registrations is much lower than expected. Since the deadline is approaching, industry representatives addressed their concerns during the latest meeting with the Ministry about completing KKDIK chemical substance registrations by 31 December 2023. 

The TOBB (Union of Chambers and Commodity Exchanges of Turkey) and the Ministry discussed proposed timelines for the chemical substance registrations under KKDIK. After that, a draft was published on 14th November 2023 for consultation and obtaining insights from industry representatives. The discussions between govermental stakeholders is still ongoing. 

The main objective of this draft for KKDIK is to determine different deadlines for different tonnage bands as the UK is experiencing with UK REACH. 

Key points from this KKDIK draft:

Ministry representatives explained that the deadlines for pre-registration will most likely to be extended until the end of the timeline.

31 December 2026:

Substances manufactured or imported in an annual amount of 1000 tonnes or more.

Substances falling within the Aquatic Acute 1 and Aquatic Chronic 1 (H400, H410) hazard categories in an annual amount of 100 tonnes or more.

Substances falling within the Carcinogenic, Mutagenic, and Reprotoxic Category 1A and 1B hazard categories in an annual amount of 1 tonne or more.

31 December 2028:

Substances manufactured or imported in an annual amount of 100 tonnes or more.

31 December 2030:

Substances manufactured or imported in an annual amount of 1 tonne or more.

At GPC, we are always ready to act on your behalf for your compliance needs with our worldwide team of experts and professionals to ensure the safety of your trade in Türkiye.

Stay tuned for updates on the KKDIK! 

On 14th November 2023, the Ministry of Environment, Urbanization, and Climate Change of Turkey announced the additional responsibilities of the registrants under KKDIK. These include changing the comp...

On 14th November 2023, the Ministry of Environment, Urbanization, and Climate Change of Turkey announced the additional responsibilities of the registrants under KKDIK. These include changing the company status or the identity information. 

As stated in the initial section of Article 22 of the KKDIK Regulation, companies undergoing registration are required to promptly revise their registration details in the event of any alterations to their status, such as transitioning to a manufacturer, importer, or goods producer. This includes updating identification information like address and company name. Article 59 (1) of the KKDIK Regulation specifies that registrants are liable to incur fees for essential changes to their approved registration documents.

Therefore, businesses that make changes to the information provided after submitting the registration dossier must obtain an application number from https://donersermaye.csb.gov.tr/.

To find out more about your responsibilities and to get support you are more than welcome to contact us!

As the KKDIK deadline is rapidly approaching, we have gathered some insights for you to understand this process better.   On the 21st of September, we had a meeting with the Turkish Ministry of En...

As the KKDIK deadline is rapidly approaching, we have gathered some insights for you to understand this process better.  

On the 21st of September, we had a meeting with the Turkish Ministry of Environment, Urbanization, and Climate Change (MoEUCC) regarding the KKDİK deadline (Türkiye REACH). After that, the Ministry and sector representatives had another meeting that addressed their concerns about the completion of KKDIK chemical substance registrations by December 31, 2023. In this meeting, TOBB (Union of Chambers and Commodity Exchanges of Turkey) and the Ministry discussed proposed timelines for the chemical substance registrations under KKDIK. 

In summary, there has been no official announcement from the Ministry regarding the postponement of the final registration date for KKDIK. However, the latest updates indicate that a draft plan to extend the deadline for KKDIK pre-registration notifications and registration dossier processes is being considered.

Stay tuned for updates on the postponement of the KKDIK process and current information!