SAFEGUARDS | Consumer Products NO. 157/18
On November 14, 2018, Turkey published Number 30595 in the Resmi Gazete  to regulate persistent organic pollutants (POPs) or kalici organic kirleticiler (KOK) in Turkish. The objectives for POP chemicals in the new law are:
- To prohibit their manufacture, placing on the market or use
- To eliminate or restrict their use
- To minimize their emission
- To manage their waste
This new piece of legislation contains a number of important provisions, including seven annexes for the management of POP chemicals. These are:
- Annex 1 ‘Prohibited substances list
- Annex 2 ‘Restricted on its own, in mixtures or articles’
- Annex 3 ‘List of substances subject to emission reduction’
- Annex 4 ‘List of substances subject to waste management’
- Annex 5 ‘Waste management’
- Annexes 6 and 7 ‘Notification forms’
The new law mirrors many of the provisions for regulated POP chemicals under Regulation (EC) 850/2004  in the European Union (EU). Many of the POP chemical names under Annexes 1 to 5 in the Turkish legislation are also identical to those in the EU legislation on POPs. The scope and requirements between the two pieces of legislation are largely similar.
It is interesting to note that Turkey has listed the following chemicals under its POP legislation:
- Dicofol, a pesticide (CAS 115-32-2) used in agriculture, is a prohibited substance under Annex 1
- Decabromodiphenyl ether (commercial mixture of Deca-BDE, CAS 1163-19-5), used as a flame retardant in a wide variety of applications, including in adhesives, coatings, inks, plastics, textiles and sealants, is a restricted substance under Annex 2. This chemical is listed under Annex A (elimination) in the Stockholm Convention 
In the EU, Deca-BDE is restricted under entry 67 to Annex XVII of EU REACH (Safeguard 27/17 ). It is important to note that the scope and requirements for this chemical are not identical between the Turkish POP legislation and Annex XVII of REACH.
There are two effective dates in Turkey’s new law. These are:
- November 14, 2018 (date of entry into force) for POP legislation other than points (2) and (3) below
- May 14, 2019 for prohibited POP chemicals listed in Annex 1 that are in articles
- May 14, 2019 for restricted POP chemicals listed in Annex 2 that are in articles
Highlights of some restricted POP chemicals and their requirements under Annex 2 of the new law in Turkey are summarized in Table 1.
|Regulation on Persistent Organic Pollutants (POPs)
Number 30595 of November 14, 2018, Resmi Gazete,
Representative POP chemicals
|Item||Substance (CAS)||Highlights of Scope and Requirement|
|1||Tetrabromodiphenyl ether*, **||≤ 10 mg/kg in substances, mixtures, articles or parts thereof for each of items 1 to 5|
|2||Pentabromodiphenyl ether*, **|
|3||Hexabromodiphenyl ether*, **|
|4||Heptabromodiphenyl ether*, **|
|5||Decabromodiphenyl ether*, **|
|6||Perfluorooctane sulfonic acid and its derivatives (PFOS)||≤ 0.001% in substances or mixtures|
|< 0.1% in semi-finished products or articles, or parts thereof|
|< 1 μg/m² in coated textiles or materials|
|7||Hexabromocyclododecane (HBCDD) and its main isomers (α-, β- and γ-HBCDD)||≤ 100 mg/kg in substances, mixtures, articles or parts thereof|
|8||Short chain chlorinated paraffins (C10-C13, SCCP)||< 1% in substances or mixtures|
|< 0.15% in articles|
|*< 0.1% for recycled materials
**Electrical and electronic equipment under Number 28300 of May 22, 2012 in Resmi Gazete  are exempt
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