Turkey Reach Regulation for Various Sectors

On June 23, 2017 the Turkish Ministry of Environment and Urbanization (MoEU) published a regulation named Kimyasalların Kaydı, Değerlendirilmesi, İzni ve Kısıtlanması Hakkında Yönetmelik (Bylaw on Registration, Evaluation, Authorization and Restirction of Chemicals) on Official Gazette Rep. No: 30105 for the management of substances, very similar to the EU REACH

Regulation, (EC) No 1907/2006.

The KKDIK regulation came into effect on December 23, 2017.

KKDIK-TURKEY REACH replaces three existing Regulations:

The purpose of KKDIK is:

• To regulate the administrative and technical procedures and principles regarding the registration, evaluation, authorization and restriction of
• To ensure a high level of protection of human health and the
• To promote use of alternative methods for assessment of hazards of substances while enhancing competitiveness and

Scope of KKDIK:

KKDIK covers manufacturing, placing on the market or use of the substances on their own, in a mixture or in an article and placing the mixtures on the market unless they are:

• Wastes
• Radioactive materials and wastes
• Substances used in defense industry
• Non-isolated intermediates
• Substances under transport and subject to customs
• Substances in freezones or temporary storage waiting to be re-exported

All substances that are in scope of KKDIK have to be registered and pre-registered if they are produced or imported more than 1 ton per year unless they are exempt. Substances that are not pre-registered until the deadline will not be allowed to be placed in the Turkish market until their registration is complete.  Substances that are not registered in time will not be allowed to be placed in the market

Who can register?

• Manufacturers
• Importers
• Non-Turkey manufacturers can appoint an “Only Representative (OR)” similar to EU REACH for the pre- registration and registration

Applicable Deadlines:

• Pre-registration under the KKDIK has to be completed according to the timeline soon to be published by the Ministry in a circular or similar official communication
• The tonnage bands for registration are similar to EU REACH (1-10; 10-100; 100-1000 and 1000+ tons/year for full registration and <1000 or >1000 tons/year for intermediate registration).
• The deadline for the final registration within KKDIK depends on the tonnage band and substance classification:
  • 31^st December 2026: 1000+ tons/year, 100+ tons/year if substance is aquatic chronic/acute 1, 1+ tons/year if substance is CMR 1A/B
  • 31^st December 2028: 100+ tons/year
  • 31^st December 2030: 1+ tons/year

• A natural person or legal entity established physically in TURKEY
• Equipped with sufficient knowledge in the practical handling of the substances and information related to them (CICR/KEK, CLP/SEA, SDS/GBF, TURKEY-REACH/KKDIK, BPR, PPPR, related TR )
• Appointed by a mutual agreement with a manufacturer, formulator or article producer, established outside Turkey
• Responsible for complying with the legal requirements for importers under TURKEY-REACH (KKDIK)
• Only representatives can represent more than one non-TR supplier, but must keep the information related to each of them
• The non-TR company has to inform the importer (s) within the same supply chain of your appointment as an only These importers are then regarded as downstream users for TURKEY-REACH.

Classification :

• Use of harmonized classification if possible;
• Propose harmonized classification when appropriate;
• Notify classification and labelling info to the Ministry of Environment and Urbanization (MoEU);

Labelling Requirements in Turkey :

• Standard GHS label elements;
• Language: in Turkish
• Additional info: nominal quantity needs to be displayed on labels;
• Words such as "non-toxic or not harmful" are not

SDS Requirements in Turkey:

• Standard 16-section SDSs;
• Must be prepared in Turkish
• Must be prepared by certified SDS experts in Turkey;
• A copy of SDSs shall be submitted to the Ministry of Environment and Urbanization (MoEU). Note: an expert holding a current certificate cannot prepare new SDSs before he/she receives new

Turkey has implemented GHS with different deadlines set for substances and mixtures. Chemical Classification criteria, labeling and SDS requirements are mainly set by the following two regulations:

• Regulation on the Classification, Packaging and Labeling of Hazardous Materials and Products - Turkish CLP Regulation;
• Regulation on the Preparation and Distribution of Safety Datasheet for Hazardous Materials and Products - Turkish SDS Regulation;

MoEU Fees:

Fees will be determined annually and published at the website

of the Ministry of Environment and Urbanization (MoEU).