Speciality Chemicals Magazine JUL / AUG 2023 | Page 34

REGULATION & COMPLIANCE
and data holder . The LoA grants you access to the jointly submitted data and allows you to refer to it in your registration dossier 4 . Develop a registration dossier that includes information on the identity of the substance , its classification and labelling , uses , exposure scenarios and hazard data 5 . Pay the registration fee as required by the Ministry of Environment & Urbanisation . The fee amount may vary depending on the tonnage band and the complexity of the registration 6 . Submit the completed registration dossier to the relevant authority , following the specified submission requirements and formats . Ensure that the dossier is complete , accurate and meets the prescribed standards to avoid delays or rejection 7 . Registration number : Upon successful evaluation of the registration dossier , you will receive a registration number . This serves as proof of registration and allows you to place the substance on the market in compliance with KKDIK It is important to note that the registration process may vary depending on the specific requirements and updates from the ministry . Staying informed about the latest guidelines and regulations is crucial for a successful registration process . Consulting with experts and seeking professional support can greatly facilitate and streamline the registration process .
Challenges
The registration process under KKDIK can present various challenges . The first is communication up and down the supply chain to identify the substances in your inventory that need to be pre-registered or registered can be a complex task . Ensuring effective communication and cooperation among suppliers , importers and downstream users is essential to gather accurate information on substances and their registration status .
Secondly , in joint registration scenarios , gaining access to necessary
Manufacturer
Registration CSR preparation
SDS preparation and distribution
Communication throughout the supply chain
Figure 2 - Responsibilities in registration process
data from data holders or owners can be challenging . Negotiating and obtaining LoAs or access to relevant data can require extensive coordination and agreement with other registrants .
KKDIK is written in Turkish . Therefore , language barriers may arise when dealing with international suppliers , consultants or authorities . Overcoming language barriers and ensuring effective communication can be essential for understanding requirements , exchanging information , and navigating the registration process smoothly .
Identifying an OR or finding a consultant with the required qualifications and expertise within the specified timeframe can be a challenge . ORs play a crucial role in fulfilling the registration obligations on behalf of non-Turkey based suppliers . It is also critical for successfully navigating the registration process .
Addressing these challenges requires proactive planning , effective communication strategies and collaboration with relevant stakeholders . Seeking support from experienced consultants or professionals who are familiar with KKDIK
Importer
Registration CSR preparation
SDS preparation and distribution
Communication throughout the supply chain can provide valuable assistance in overcoming these hurdles and ensuring a smoother registration process .
Conclusion
The KKDIK regulation stands as a testament to Turkey ’ s commitment to chemical safety . By encompassing a wide range of substances and incorporating various roles , it ensures comprehensive compliance .
Stakeholders must recognise the importance of the regulation and diligently adhere to its requirements . By doing so , they contribute to creating a safer chemical environment in Turkey and join the global effort to protect human health and the environment from the hazards of chemicals .
Greenovation highly advise you to start early and allocate sufficient time and resources to complete that process effectively . We are here to support you in overcoming challenges and achieving a seamless registration process under KKDIK ●
İlkay Çetin
MANAGING DIRECTOR
GREENOVATION
Downstream user
CSR preparation
SDS preparation and distribution
Inform suppliers if they have new information on the hazards or risks
k + 34 692 691 656 J ilkay @ greenovationconsulting . com j www . greenovationconsulting . com /
34 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981