An EU Reach-like regulation is being implemented in Turkey (not an EU Member State) at the end of 2020. Like Reach, the new regulation (named KKDIK) requires that substances are “pre-registered” in Turkey (by a Turkish Legal Entity) before the end of 2020.
English versions of the The KKDIK regulation can be found in draft form at the site of the Turkish General Directorate of Environmental Management, as below
Key points of the forthcoming regulation are :
• Pre-registrations need to be done by end 2020
• Registration and submission of dossiers will happen from 1.1.2021 to 31.12.2023. The registration process and costs are not defined yet
• Like EU-Reach, registration is substance-based and not product-based.
• Some substances are exempted if natural (e.g. in EU Reach Annex IV and V)
• Polymers exempted, but monomers need registration
• SDS need to be revised between now and 31.12.2023, following related Turkish regulation
There are several key actions for those importing chemicals into Turkey :
1) Review product range by substance. Then, if possible, buy formulants from sources who have already registered, or will register, in Turkey.
2) Check if Turkish importer will support registrations on your behalf. This may work if the exporter to Turkey has only one importing company. It may involve providing formulation details to the importer, which could lead to confidentiality issues for some exporters to Turkey. However, there are solutions to this.
3) Exporter to Turkey appoints an Only Representative who is a Turkish Legal Entity. This approach may be more expensive, but would cover all imports of specific substances, by all importers.
Linmark Consulting does not have a Turkish Legal Entity, but manages the process on behalf of companies through its global network. The EU-Reach part of the process is critical to consider for European producers wishing to export to Turkey.
Link for English documents: https://kimyasallar.csb.gov.tr/mevzuat/54