Doruk Sistem - KKDIK / TURKREACH

About KKDIK

KKDIK is a regulation of TURKIYE (TR), adopted to improve the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of TURKISH chemicals industry. It also promotes alternative methods for the hazard assessment of substances in order to reduce the number of tests on animals. 

Turkish Regulation on Registration, Evaluation, Authorisation and Restriction of Chemical substances

TURKREACH KKDIK is the Turkish Ministry of Environmental, Urbanisation and Climate Change (MoEUCC) Regulation on chemicals and their safe use, which is published on 23rd June, 2017. It deals with the Registration, Evaluation, Authorisation and Restriction of Chemical substances.

TURKREACH KKDIK addresses the use and production of chemical substances, and their potential impacts on both the environment and human health.

TURKREACH KKDIK is the most comprehensive and stringent Turkish chemical legislation to date. TURKREACH KKDIK requires all companies producing chemical substances in Turkey or importing them in quantities over one tonne per year to register these substances with the Turkish Ministry of Environmental, Urbanisation and Climate Change (MoEUCC).

The registration is only one aspect of the Regulation, Evaluation and Authorisation/Restriction being the complementary ones.

KKDIK/TURKREACH

KKDIK/TURKREACH requires manufacturers and importers of chemical substances (larger than or equal to 1 tonne/year) to obtain information on the physicochemical, health and environmental properties of their substances and use it to determine how these substances can be used safely. Each manufacturer and importer must submit a registration dossier documenting the data and assessments to MoEUCC.

In principle, KKDIK applies to all chemical substances; not only those used in industrial processes but also in our day-to-day lives, for example in cleaning products, paints as well as in articles such as clothes, furniture and electrical appliances. Therefore, the regulation has an impact on most companies across TURKIYE.

KKDIK places the burden of proof on companies. To comply with the regulation, companies must identify and manage the risks linked to the substances they manufacture and market in TURKIYE. They have to demonstrate to MoEUCC how the substance can be safely used, and they must communicate the risk management measures to the users.

If the risks cannot be managed, authorities can restrict the use of substances in different ways. In the long run, the most hazardous substances should be substituted with less dangerous ones.

How does KKDIK work?

KKDIK establishes procedures for collecting and assessing information on the properties and hazards of substances.

Companies need to register their substances and to do this they need to work together with other companies who are registering the same substance.

KKDIK receives and evaluates individual registrations for their compliance, and TR Authority evaluate selected substances to clarify initial concerns for human health or for the environment. MoEUCC’s scientific committees assess whether the risks of substances can be managed.

Authority can ban hazardous substances if their risks are unmanageable. They can also decide to restrict a use or make it subject to a prior authorisation.

KKDIK's effect on companies

KKDIK impacts on a wide range of companies across many sectors, even those who may not think of themselves as being involved with chemicals.

In general, under KKDIK you may have one of these roles:

Manufacturer: If you make chemicals, either to use yourself or to supply to other people (even if it is for export), then you will probably have some important responsibilities under KKDIK.

Importer: If you buy anything from outside the TR, you are likely to have some responsibilities under KKDIK. It may be individual chemicals, mixtures for onwards sale or finished products, like clothes, furniture or plastic goods.

Downstream users: Most companies use chemicals, sometimes even without realising it, therefore you need to check your obligations if you handle any chemicals in your industrial or professional activity. You might have some responsibilities under KKDIK.

Companies established outside the TR: If you are a company established outside the TR, you are not bound by the obligations of KKDIK, even if you export their products into the customs territory of TURKIYE. The responsibility for fulfilling the requirements of KKDIK, such as registration lies with the importers established in TURKIYE, or with the only representative of a non-TR manufacturer established in TURKIYE.

Registration

MoEUCC will perform dossier evaluation to assess testing proposals made by the registrant or to check that the registration dossiers comply with the requirements. MoEUCC will also co-ordinate substance evaluation, which will be conducted by the Member States to investigate more in depth chemicals of concern.

Authorisation

Authorisation is required for the prioritised substances of very high concern (SVHC). Companies applying for authorisation will have to demonstrate that risks associated with uses of these substances are adequately controlled or that the socio-economic benefits from their use outweigh the risks.
Applicants will also have to investigate the possibility of substituting these substances with safer alternatives or technologies, and prepare substitution plans, if appropriate.