How to place chemical products on the market in Türkiye

The Turkish Ministry of Environment, Urbanisation and Climate Change (MoEUCC) introduced KKDIK (Türkiye REACH) on 23rd June 2017. Similarly to the EU REACH regulation, companies that manufacture and/or import substances in Türkiye equal to or above 1 metric tonne annually are required to register these before placing them on the market. Originally, the deadline for all substances imported or manufactured at 1 metric tonne or more per annum to be registered was 31st December 2023.

However, on 23rd December 2023, the MoEUCC published an amendment which officially extended the Türkiye REACH registration deadlines, due to concerns surrounding lack of lead registrants claimed and data-ownership issues.

To avoid a repeat of the confusion and anxiety caused by the last-minute nature of the delay, companies are advised to review their inventories, check their market forecasts and seriously consider taking on the lead registrant role to protect their market.  While companies do not need to register until the deadlines below, the work to organise the registration dataset, dossier and risk assessment should begin in plenty of time so that potential lead registrants can work with potential joint registrants to ensure a healthy and prompt reimbursement of the registration costs.

The extended deadlines vary according to tonnage band and hazard category:

If any of your substances meet the above criteria, you will need to ensure you have registered by the relevant deadline to continue placing products on the Turkish market.

To submit registrations to the KKS system, you must have a legal entity within Türkiye as only Turkish citizens can access the system.

Solutions for your business

Ricardo can help you successfully comply with the requirements of Türkiye REACH by:

• Tracking your chemical inventory and supply chain to ensure the need for registration and the correct registration level are promptly identified.
• Acting as a single point of contact for the registration.
• Preparing the full registration dossier, either lead and/or joint registration.
• Project managing the translation and submission of registration dossiers to the KKS system through our partnership with Turkish consultants. 
• Providing support in monitoring and communication of SIEF activities.
• Providing ad-hoc consultancy advice regarding Türkiye REACH.
• Ensuring any future requests or requirements from the Turkish Competent Authorities are addressed and met to keep your substances on the market.

SDS & Emergency Response Number

As with EU REACH, SDS are required to be provided by Türkiye REACH, which closely mirrors the EU requirements. There are, however, some important differences to the EU requirements. Firstly SDS must be prepared and signed off by a local certified Chemical Assessment Expert and translated into Turkish. Secondly the SDS must be uploaded to the Ministry Integrated Environmental Information System (EÇBS) by local suppliers.

Also as for EU REACH, requirement for an Emergency Response Telephone number in Section 1 of the SDS is included. Whilst it is important to include a Poison Centre telephone number, best practice is to consider the full range of potential incidents, including spillages and fires and include an emergency response telephone number that can support these also.

Ricardo’s partner in Türkiye can help you to meet these requirements by preparing and signing these SDS, and supporting companies to upload them through the local portal.

Poison Centres

The SEA Regulation mirrors CLP in Türkiye and requires classification and labelling of hazardous chemicals. SEA was updated in 2020 to include a new requirement to make poison centre notifications under Article 44/A, with a planned enforcement date of the 01.01.2025. However, the competent authority has not yet published any guidance or tools related to submitting Poison Centre Notifications, and it is expected that the deadline will be extended. Ricardo’s Poison Centre team is monitoring this situation closely and will provide support to our customers as and when this regulation is enforced.

Our team of experienced chemical regulatory experts can explainhow Turkyie REACH impacts your organisation, and the solutions available to support you. Contact us today >