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SAFEGUARDS | Consumer Products NO. 102/17

SafeGuardS Laboratory equipment

Turkey has recently published regulations for the management of substances, similar to the EU’s REACH legislation. The new law enters into force on December 23, 2017.

On June 23, 2017, the Turkish Ministry of Environment and Urbanization published a EU REACH-like Regulation (Kimyasalların Kaydı, Değerlendirilmesi, İzni Ve Kısıtlanması Hakkında Yönetmelik, KKDIK [1]) under Number 30105 (Repeat) in the Resmi Gazete, the Official Gazette of the Republic of Turkey.

This landmark piece of legislation will repeal three existing laws. These are:

  • Regulation Number 29204, dated December 13, 2014, on Safety Data Sheets for Hazardous Substances and Mixtures
  • Regulation Number 27092, dated December 26, 2008, on Inventory and Control of Chemicals
  • Regulation Number 27092, dated December 26, 2008, on the Restriction of Hazardous Substances and Mixtures.    

KKDIK is modeled on REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), a comprehensive piece of legislation for the management of substances in the European Union (EU). There are a number of important provisions in this new law, including:

  • Pre-registration and registration of substances
  • The use of an ‘Only Representative (OR)’ for non-Turkey manufacturers
  • There are four tonnage bands (1-10 tonnes/year, 10-100 tonnes/year, 100-1000 tonnes/year and more than 1000 tonnes/year)
  • Chemical safety reports are required to be signed by a chemical safety expert. This is an important difference between KKDIK and REACH
  • Requirements for 16-section safety data sheets (SDSs) in Turkish using the Global Harmonised System (GHS)
  • To establish a Candidate List of Substances for inclusion in Annex XIV (similar to Candidate List of Substances of Very High Concern (SVHCs) for Authorization in REACH)
  • To establish an Authorization List (Annex XIV)
  • Notification of substances in articles (similar to Candidate List of SVHCs in REACH)
  • Restrictions under Annex XVII. This list is not as complete as Annex XVII of REACH but the numbering system for the 66 entries is consistent with Annex XVII of REACH. The effective dates are:
  1. December 23, 2017 for entries other than those listed below
  2. December 31, 2018 for entries 28 to 32, 34 to 38, 40, 41, 45, 48, 49, 54, 55, 57, 58 and 60.
  3. December 31, 2019 for entry 62
  4. December 31, 2021 for entries 46a (nonylphenol ethoxylates, NPEs), 65 (inorganic ammonium salts) and paragraphs 1-4 to entry 47 (chromium (VI) relating to cement)
  5. December 31, 2022 for entry 66 (bisphenol A, BPA)

The new law will enter into force on December 23, 2017.

Highlights of some important provisions in the new law are summarized in Table 1.

Item Scope Requirement Effective Date / Deadline
1 Pre-registration Substance meeting criteria for registration By December 31, 2020
2 Registration
(Articles 7 and 8)

Substance on its own or in mixture

  •  1 tonne or more per manufacturer or importer per year
By December 31, 2023

Substance in article

  •  Intended to be released and in a quantity of 1 tonne or more per manufacturer or importer per year
3 Restriction (Annex XVII)

A list of 66 entries restricting or prohibiting the use of certain substances in specified applications.

The list of substances includes, but not limited to, azo dyes, BPA, cadmium, lead, nickel, organotins, phthalates and polycyclic aromatic hydrocarbons (PAHs).

In phases, starting December 23, 2017

SGS will follow up and inform interested parties as developments on REACH and KKDIK regulations occur. Our expertise combined with consultancy services and experience in consumer product supply chains provides a central point of contact for global solutions. If you would like to learn more about how SGS can support your REACH compliance activities please visit www.sgs.com/reach

For enquiries, please contact:

Yeşim Demir
Technical Projects Leader
t: (+90) 212 368 40 00 (Ext 4205)

Hingwo Tsang
Global Information and Innovation Manager
t: +852 2774 7420

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