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As the deadline for pre-registration under Turkey’s KKDIK regulation approaches, businesses need to be well-prepared to meet their obligations and navigate the complex world of chemical compliance. KKDIK, an equivalent of the EU REACH Regulation, is designed to ensure the safe handling and management of chemical substances in Turkey. With the pre-registration deadline set for December 31, 2020, businesses must act swiftly to fulfill their obligations. In this article, we address some of the most frequently asked questions about KKDIK to provide clarity and guidance.
- How Are Polymers Processed Under KKDIK?
KKDIK, similar to EU REACH, exempts polymers themselves from registration. Instead, the focus is on the monomer units and other substances present in quantities of 1 ton/year or more, which require pre-registration or full registration.
- Is Individual Substance Notification Required for Chemical Mixtures?
For chemical mixtures, classification is determined by whether the mixture contains a hazardous substance above the specified concentration limit. If a mixture meets the hazardous criteria, C&L notification is necessary, similar to EU REACH.
- Can Completed Pre-Registrations Be Transferred?
The online platform for submitting pre-registration/registration dossiers is currently being updated. After the update is complete, the transfer function for Only Representatives will become available.
- Can Substances Under 1 Ton/Year Still Be Pre-Registered?
Pre-registration is possible for substances that fall below the 1 ton/year threshold. This also covers future business in case annual tonnages increase beyond 1 ton/year within three years. Failing to pre-register by December 31, 2020, and witnessing tonnages rise above the 1 ton/year threshold would result in the need for full registration, incurring higher costs.
- Is There a System for Reporting Dispatches Into Turkey After Pre-Registration?
As of now, there is no established system for reporting dispatches into Turkey after pre-registration.
- Can the Pre-Registration of Raw Materials Be Utilized by the Formulator of a Mixture?
The ability to utilize pre-registration numbers for raw materials rests with the supplier who obtained the pre-registration number. It is at their discretion to allow formulators to use the pre-registration number.
- Who May Register in the Case of Multinational Companies or Group Companies?
The registration process in the case of multinational companies or group companies depends on whether each company falls under the definition of ‘registrant’ as defined in Article 4(ü) of the KKDIK regulation. If multiple companies are part of the same legal entity, only one company needs to act as the registrant. However, separate legal entities, like sister companies, should also register.
- How Are Alloys Registered?
According to KKDIK, alloys are treated similarly to mixtures. Each individual metallic substance must be registered individually.
- Can a Higher Tonnage Band Be Registered if Anticipated Tonnages Increase?
Companies may register under higher tonnage bands if they expect their annual tonnage to increase. However, they must pay the higher registration fee and provide all the required information for the higher tonnage band, as data requirements differ between tonnage bands.
- How to Determine if Components of a Mixture Have Already Been Registered by the Supplier?
If a supplier refuses to share information on registered components of a mixture, there are several options:
– Contact the formulator if the supplier is not the same entity as the formulator, as they may be more willing to share composition information.
– Conduct analytical measurements to determine the composition of the mixture.
– Find an alternative supplier willing to share the information.
- Can Pre-Registration Be Processed with CAS No. Only?
Yes, pre-registration can be processed with CAS No. only; there is no requirement for an EC No.
- Can Distributors Outside Turkey Appoint an Only Representative and Process Pre-Registration?
Distributors located outside Turkey, like manufacturers under EU REACH, can appoint an Only Representative and process pre-registration.
- Is There a Distinction Between “Existing Chemical” and “New Chemical” in KKDIK?
KKDIK does not provide specific definitions for “Existing Chemical” and “New Chemical.” It focuses on substances rather than making this distinction. Therefore, CIRS suggests companies process pre-registration for all their substances.
14- Is Pre-Registration Required for Raw Materials That Are Not Residual?
If raw materials are not present as residues and are intentionally included, pre-registration is not required.
- How Should a Turkish Legal Entity with Multiple Factories Process Pre-Registration?
Under KKDIK, the registrant must be a natural or legal person in Turkey. If a single legal entity owns different factories with no separate legal entities, a single pre-registration is sufficient to cover all factories.
Conclusion
Navigating the complex landscape of KKDIK requires a thorough understanding of the regulation and careful compliance planning. The pre-registration deadline is fast approaching, and businesses must act promptly to fulfill their obligations. While this article addresses some of the most frequently asked questions, it is crucial for businesses to stay informed and consult with experts to ensure full compliance with KKDIK. If you have additional questions or require further guidance, do not hesitate to contact experts who can provide you with the necessary support and knowledge to navigate KKDIK successfully.