What is the Regulation on the Registration, Evaluation, Authorization, and Restriction of Chemicals (KKDİK)?
The Regulation on the Registration, Evaluation, Authorization, and Restriction of Chemicals, also known as KKDİK or Turkish REACH, was published by the Ministry of Environment and Urbanization and Climate Change on June 23, 2017.
Although KKDİK is based on the EU REACH regulation, it includes some specific differences for implementation in Turkey.
The main purpose of KKDİK is to ensure a high level of protection for human health and the environment, promote alternative methods for assessing the hazards of substances, enhance competitiveness and innovation, and regulate the administrative and technical procedures for the registration, evaluation, authorization, and restriction of chemicals.
Under KKDİK, also known as Turkish REACH, there is a registration obligation for substances manufactured in or imported into Turkey in quantities of one ton or more per year either on their own or in mixtures. However, substances exempted under the EU REACH regulation are also exempted under KKDİK.
Some important notes about KKDİK:
The pre-registration process for chemical substances started on December 23, 2017, and ended on December 31, 2020.
The registration process started on January 1, 2021, and will end on December 31, 2023.
Monomers must be registered according to the definition and conditions specified in the EU REACH regulation, while polymers are exempt from registration.
Substances that are not registered, and are present in quantities of one ton or more per year, either on their own or in mixtures or articles, cannot be manufactured or imported into Turkey or placed on the market after December 31, 2023. After January 1, 2024, substances intended to be manufactured or imported in quantities exceeding one ton per year must complete the registration process before being placed on the market.
ProSCon provides the following services under KKDİK:
Conducting an inventory study of chemicals in the facility and identifying substances subject to registration.
Making registrations through the Chemical Registration System (KKS) after identifying the substances.
Monitoring and reporting on Substance Information Exchange Forums (SIEFs).
Some terms mentioned in the KKDİK Regulation:
Manufacturer: A natural or legal person established in Turkey who manufactures a substance.
Importer: A natural or legal person established in Turkey who is responsible for the import.
Downstream User: A natural or legal person other than the manufacturer or importer who uses a substance on its own or in a mixture for their industrial or professional activities and is not a distributor or consumer, established in Turkey.
Distributor: A natural or legal person, including a retailer, who only stores and places a substance on the market on its own or in a mixture for third parties, established in Turkey.
Supplier: A manufacturer, importer, downstream user, or distributor who places a substance or a mixture on the market on its own or in a mixture.
Actors in the supply chain: All manufacturers and/or importers and/or downstream users in the supply chain.
Substance: A chemical element and its compounds, excluding substances that occur in a natural state and substances used as solvents, which can be isolated from the mixture, even if used to stabilize the substance, including impurities arising from the production process and additives used to preserve the substance’s stability and structure.
Mixture: A mixture or solution composed of two or more substances.
Article: An object with a special shape, surface, or design determined to determine its function during production, regardless of its chemical structure.
Intermediate: A substance manufactured for conversion to another substance or used in chemical processes.
Exposure scenario: A set of conditions that define the manufacture or use of a substance and describe controls on exposure to the substance or advice for downstream users on how to control exposure, including operational conditions and risk management measures.
gGBF – Extended Safety Data Sheet: An extended Safety Data Sheet (gGBF) with added exposure scenarios.
Annual Quantity: For substances that are manufactured or imported in consecutive three calendar years, it is the average of the quantities manufactured or imported in the preceding three consecutive calendar years. For substances that are not manufactured or imported in consecutive three calendar years, it is the quantity of the calendar year with the highest manufacturing or import volume.
Regulations Related to KKDIK:
Regulation on Health and Safety Measures for Working with Chemical Substances
Regulation on the Classification, Labeling, and Packaging of Substances and Mixtures
KKDIK – Regulation on the Registration, Evaluation, Authorization, and Restriction of Chemicals
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Takipte Kalın
It seems like you are stating that you are registering the chemicals in your company within the framework of legal regulations. Additionally, you mention that starting from the year 2024, you will carry out the necessary work under the KKDIK regulation.