Speciality Chemicals Magazine JAN / FEB 2021 | Page 62

Dr Yaprak Yüzak Küçükvar , director of REACH Global Services , summarises the current regulatory environment in Turkey for global companies with an interest in the Turkish market

Compliance with Turkey ’ s

REACH-like regulation

Dr Yaprak Yüzak Küçükvar , director of REACH Global Services , summarises the current regulatory environment in Turkey for global companies with an interest in the Turkish market

While the uncertainty on how

long the economic impact of the COVID-19 pandemic on the chemicals and related industries around the world will continue , compliance with various chemicals regulations still remains an obligation for manufacturers willing to place their chemicals on different regional markets . Although chemical regulations may slightly differ from region to region , many of them are based on the EU REACH regulation .
Registration has begun
Turkey is one of the countries that have been hit by the costly compliance requirements of EU REACH directly and indirectly since 2008 . Several Turkish manufacturers chose to register substances through an only representative ( OR ) in order to continue exporting to the European Economic Area ( EEA ). Now they face a new challenge within their own local market . The Ministry of Environment & Urbanisation ( MoEU ) finally implemented the Turkish REACH regulation ( KKDIK ) in June 2017 . A preregistration period which began before the end of 2017 , ended recently , opening a window of a registration period that began on 1 January 2021 and will close on 31 December 2023 ( Figure 1 ). All substances in the market will be KKDIK registered after 2023 which is a part of the ‘ No Data , no market ’ principle . Current regulations in force in Turkey , namely KKDIK , and the by-law on Classification , Labelling & Packaging of Substances & Mixtures ( SEA ), are the results of regulatory approximation within the ongoing legal relationship with and the EU . Under KKDIK , any manufacturer or importer of a substance on its own or in a mixture in quantities of one ≥1tonne / year must submit a registration dossier to the MoEU through a dedicated Chemicals Registration System ( KKS ). KKDIK also affects non-Turkish manufacturers , who are importing chemicals in growing volumes - $ 31 billion in value in 2019 . The decisions made over KKDIK compliance will eventually result in changes in supply chains . Formulators , who play a big role in Turkish chemicals exports ( valued at $ 15 billion in 2019 ), are very much dependent on the KKDIK compliance for the imported substances . The last few months of 2020 were therefore critical , as all manufacturers and importers worked hard to determine their business strategies and preregister the substances on the KKS before 31 December . Whilst KKDIK is a translation of EU REACH with adaptations to Turkish laws , late pre-registration
Figure 1 – Timeline of KKDIK
62 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981