REGULATION & COMPLIANCE
• Importer compliance : The OR is responsible for ensuring compliance with the legal requirements for importers under KKDIK . This includes fulfilling registration , notification and other regulatory obligations on behalf of the non-Turkish suppliers
• Informing importers : The non- Turkish company must inform the importer ( s ) within the same supply chain about the appointment of the OR . These importers are then considered downstream users under KKDIK . This communication ensures transparency and compliance within the supply chain Selecting a competent and knowledgeable OR in Turkey is essential for ensuring effective KKDIK compliance . Greenovation Consulting itself offers these services through a team experienced in navigating the complexities of the regulatory landscape and will provide you with comprehensive guidance tailored to your specific needs .
Other registration issues
Joint registration presents a significant opportunity for stakeholders to streamline their efforts and minimise duplication of testing and data generation . By participating in joint registration , multiple manufacturers or importers of the same substance can share data and costs .
This cooperative approach significantly alleviates the burden
Non-Turkey based manufacturer
Only Representative
Manufacturer
Turkey-based manufacturer
Third party representative on individual registrants and is encouraged by the Turkish authorities . Lead registrants of joint submissions play a crucial role in facilitating the process , ensuring comprehensive data submission and effective coordination among the joint registrants .
KKDIK enforces the ‘ No registration , no market ’ principle . This means that substances that have not been registered or notified in compliance with KKDIK by the end of 2023 cannot be placed on the Turkish market . To ensure compliance and legal market access , companies are required to fulfill their registration obligations by the beginning of 2024 .
Where to start ?
To start the registration process under KKDIK , here are the recommended steps :
• Identify inventory : Begin by creating an inventory list of all the substances your company produces and / or buys from other suppliers . This list should include detailed information about each substance , such as its chemical composition , quantities and uses
• Supplier declarations : Reach out to your suppliers and importers to request their declaration of KKDIK registration for the substances they supply to you . This information is crucial in determining whether the substances have already been registered or if registration needs to be pursued
KKDIK
Importer
Third party representative
Downstream user
Figure 1 - Roles in registration process
• Professional support : Seek professional support from consultants or experts with expertise in KKDIK compliance . They can guide you through the registration process , help you develop a registration strategy , and provide assistance in fulfilling the necessary requirements
• Registration strategy : Develop a comprehensive registration strategy in collaboration with your professional support . This strategy should outline the timeline , resources and actions required to complete the registration process successfully . It should consider factors such as substance prioritisation , data requirements and submission deadlines
• OR : Determine if appointing an OR is necessary for your registration process . If needed , select a qualified OR and establish a mutual agreement to assign them the responsibility of compliance By following these steps and leveraging professional support , you can initiate the registration process , identify the substances that require registration , and establish a systematic approach to ensure compliance with KKDIK . Remember to stay updated with the latest guidelines and regulations provided by the Ministry of Environment & Urbanisation in Turkey to ensure accurate and timely compliance .
Registration Steps to 2024
The registration process under KKDIK involves several key steps . The typical registration process runs as follows : 1 . Pre-registration : After completing pre-registration it will be possible to see all co-registrations in pre- substance information exchange forums ( SIEFs ) 2 . Join relevant SIEFs to stay updated on the latest news and developments regarding your substance . SIEFs facilitate communication and collaboration among registrants for sharing data and avoiding duplication of studies 3 . Secure Letter of Access ( LoA ) from lead registrant : By following the latest information in a SIEF you will get LoA information from the lead registrant
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