Latest updates
The KKS is under construction and process is managed by IPA project ( an instrument for pre-accession assistance ) co-financed by the EU and Turkey . This started in November 2019 and will last for two years . An IT platform with enhanced functionalities and a new interface , compatible with IUCLID latest version was introduced in early November 2020 . The KKDIK OR Change Procedure is one of the new functions under KKS and companies who need to transfer their pre-registrations to another OR need to follow a certain process . KKS is similar to REACH-IT , in that pre-registered companies will join the MBDF , equivalent to an EU REACH substance information be exchange forum ( SIEF ), and with will be able to see and communicate with other potential registrants of their substances . There is no MBDF facilitator option in KKS for the moment . The MoEU had already received more than 22,000 substances when the pre-registration period ended . For substances at 10 tonnes / year or above , a chemical safety report ( CSR ) is required as part of the registration dossier . The Chesar tool for CSR preparation will be integrated into KKS as part of the same IPA project by the end of 2021 at the latest , according to an announcement by the MoEU . Companies with a CSR obligation can choose to wait until the integration of Chesar into KKS . Meanwhile , they can continue preparing the rest of the dossier online .
Use of REACH data
All chemicals placed on the Turkish market have to be registered by 31 December 2023 , according to KKDIK .
Although the three-year registration time frame starting in January 2021 worries some companies , it is obvious that the required data for most of the substances have already been compiled in EU REACH registration lead dossiers . The MoEU also translated most of ECHA ’ s guidance documents into Turkish , including guidance on data sharing . MBDF communications have already ( LRs ) started between the preregistrants via mass e-mail exchanges . Companies willing to be the lead registrant and have ownership of data are ahead of the game . Initial discussions have already started and encouraged at some EU consortia to use the existing data sets for KKDIK registrations in order to avoid additional testing and make use of the data by providing a letter of access ( LoA ). This has already been practiced under the consortia for other global regulations , notably under K-REACH . As no agreement has been reached between the Turkish government and the European Commission regarding REACH data and the duplication of costs associated with the rights to use it in Turkey , this remains the major compliance cost and a workload ‣
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