New Regulation Related to KKDIK Registration Dossiers

On 2nd February 2023, the Ministry of Environment, Urbanization, and Climate Change of Turkey announced a new regulation related to KKDIK registration dossiers for sections 1.7 and 13.1. 

Firstly, the Turkish importers of the foreign company they represent must be listed in the "1.7 Suppliers" section of the registration dossiers. It has been determined acceptable to remove this supplier section information requirement from being an obligation after the Ministry evaluated the views and recommendations from industry associations, associations, and various organizations. In this case, even though it is advised that only representatives submit this information to the registration dossiers, not doing so will not affect the completeness check on the registration dossiers from the Ministry. However, the Ministry advises that only representatives need to keep track of the importer details in case they require them in the future. The content in the already published guides, such as "Registration Guide," "KKS User Guide," and the "Frequently Asked Questions" section in the Chemicals Help Desk, will be updated as soon as practical in this respect by the Ministry.

Secondly, section 13.1 on KKS includes Chemical Safety Reports for the registered substances. According to the Ministry, the Chemical Safety Reports, which must be included in registration files for chemicals weighing 10 tons or more annually, could cause additional costs because of the lengthy translation process, and the deadline of the registration period. In this context, as the registration deadline of December 31, 2023, is approaching, registrants could upload Chemical Safety Reports in English until then. However, registrants who prefer to upload the Chemical Safety Report in English are required to attach the translated version to the registration dossier in order to include the uses, exposure scenarios, and risk management measures in Turkey within 1 (one) year at the latest. In other words, even though English reports are accepted this year, from next year onwards Turkish reports should be prepared and included.

The deadline for KKDIK registration, 31 December 2023, is not expected to be postponed. We suggest that industry representatives should complete the process as soon as possible since substances not registered after the deadline will not be able to enter the Turkish market.