Turkey: REACH-Type Regulation Coming at the End of the Year

The Turkish Ministry of Environment and Urbanisation (MoEU) plans to publish a chemicals regulation modeled on REACH at the end of the year. The regulation, KKDIK, is the abbreviation for registration, evaluation, authorization, and restriction of chemical substances in Turkish.

According to the law, manufacturers and importers that produce or import chemical substances in a quantity greater than one ton per year must register the substances by December 31, 2018. As is the case with REACH, a no-data, no-market rule will apply. In other words, failure to comply with the law can lead to a stoppage of production and importation, which can endanger the very existence of a company.

KKDIK applies to Turkish companies, non-Turkish companies that export raw materials into Turkey, and corporate groups with subsidiaries in Turkey. Large Turkish petrochemical companies like Petkim and Tupras already have commercial relationships with the EU. They are therefore better prepared for the regulation than small and midsize companies that constitute more than 80% of the Turkish market.

Companies affected by the regulation should consider the following:

  • Safety data sheets must be maintained in Turkish.
  • Non-Turkish companies must appoint a sole representative.
  • The Turkish MoEU is the contact person and the agency responsible; it evaluates the dossiers and inspects all documents for completeness and correctness.
  • Data on existing studies as well as assessment and classification are exchanged through the Substance Information Exchange Forum (SIEF).

Representatives of the affected companies have complained about a lack of support. They claim that the guidelines and subject-matter experts needed to ensure rapid implementation of the law are unavailable. A REACH expert, Dr.Yaprak Yuzak Kucukvar of REACH Global Services S.A. (the sole representative for Petkim and Tupras) expressed his doubts that the target date at the end of 2018 could be reached, given the political turbulence of the past few months. According to the Turkish Ministry of Science, Industry and Technology, however, everything is proceeding according to plan.

The EU is an important commercial partner of Turkey. About one third of its chemical products are exported to the EU. The Turkish plastics and pharmaceutical industries are experiencing particularly strong growth. Germany Trade & Invest (GTAI: site available in German only), the society of the Federal Republic of Germany for foreign trade and location marketing provides a detailed overview of economic developments in Turkey.

KFT works for companies in Turkey and is familiar with the local legal situation. Please contact us at sds@kft.de.

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