KKDIK: The Turkish Chemical Regulation and Its Impact on the Industry

1. Objectives and Scope of KKDIK

2. Scope and Exemptions

3. IImplementation and Compliance

4. Registration Deadlines

5. Key Differences with EU REACH

6. Registration Platform and Administrative Fees

On June 23, 2017, Turkey's Ministry of Environment, Urbanization, and Climate Change (MoEUCC) introduced the KKDIK regulation, also known as TURKREACH, aimed at ensuring the safety of chemicals and chemical products. This regulation came into force on December 23, 2017, and its acronym stands for chemicals, registration, evaluation, authorization, and restriction in Turkish. Similar to the European Union's REACH regulation, KKDIK has parallel objectives and follows comparable processes, striving for high safety standards and competitiveness in the Turkish chemical industry.

Objectives and Scope of KKDIK

The overall focus of the regulation spans from registration to restriction of chemical products. Like its European counterpart, KKDIK requires companies manufacturing or importing chemical substances in Turkey in volumes exceeding one ton per year to register them with the Ministry of Environment and Urbanization (MoEU).

KKDIK shares the same fundamental objectives as the EU REACH:

• Ensure the protection of human health and the environment: Prevent risks associated with chemical substances

• Reduce animal testing: Promote alternative testing methods.

• Promote competitiveness and innovation: Strengthen the Turkish chemical industry in the global market.

Scope and Exemptions

The KKDIK regulation applies to all chemical substances, whether pure, in mixtures, or contained in articles. However, there are certain exemptions, including:

• Radioactive substances and mixtures;

• Goods in transit and in free zones for re-export;

• Non-isolated intermediates;

• Transportation of dangerous substances;

• Substances for defense purposes;

• Medicines, veterinary products, medical devices, cosmetics, food, and feed.

IImplementation and Compliance

To comply with the KKDIK regulation, companies must:

• Register applicable substances: All manufacturers, importers, and downstream users must register their chemical substances with the MoEU within the established deadlines. Foreign companies exporting chemicals to Turkey can choose to register their substances through a local exclusive representative, thus facilitating their access to the Turkish market.

• Monitor substances subject to authorization and restriction: Ensure compliance with Annexes 14 and 17 of the regulation.

• Prepare safety data sheets (SDS): These must be compliant, in Turkish, and elaborated by a chemical assessment specialist certified by the Turkish Accreditation Institution (TÜRKAK).

IMPORTANT REMARK! 

The SDS which is written according to regulation of 29204 were valid until 31st December 2023. After this date, it became mandatory the compliance of the SDSs  with the Annex II of KKDIK regulation. 

Registration Deadlines

31/12/2026

• Substances manufactured or imported in their original form, in a mixture, or in articles, in an annual quantity equal to or greater than 1,000 tons.

• Substances manufactured or imported in quantities between 100 and 1,000 tons annually, if classified under hazard classes such as Aquatic Chronic/Acute, Category 1.

• Substances classified as Carcinogenic, Mutagenic, and Toxic to Reproduction, Categories 1A and 1B, manufactured or imported in quantities equal to or greater than 1 tons annually.

31/12/2028

Substances manufactured or imported in quantities between 100 and 1,000 tons annually.

31/12/2030

Substances manufactured or imported in quantities between 1 and 100 tons annually.

IMPORTANT!

Once the registration deadlines have passed, all substances marketed in Turkey in quantities equal to or greater than one tonne per year that have not been registered must first undergo the inquiry procedure and then be registered. They can only be marketed in Turkey after completing the registration process.

Key Differences with EU REACH

One of the main differences between EU REACH and KKDIK is that the latter requires that registrations and notifications be signed only by qualified experts. Additionally, all documentation must be in Turkish, and the responsible specialists must have KDU certification, obtained through institutions accredited by TÜRKAK (Turkish Accreditation Institution).

Registration Platform and Administrative Fees

Registration under KKDIK is done through the KKS (Chemical Registration System) platform, similar to REACH-IT in the EU. Administrative fees vary depending on the registered tonnage and must be paid during the registration process.

The KKDIK regulation is a robust regulatory framework that not only protects health and the environment in Turkey but also promotes innovation and competitiveness in the country's chemical industry. For companies operating in this sector, complying with KKDIK is not just a legal obligation but an opportunity to strengthen their position in the Turkish and global markets.