SEA (CLP-TR)
Notification Obligation Under Turkish SEA (CLP) Regulation
Classification and Labeling (S&E) Notifications in accordance with the SEA regulation published in the Official Gazette dated 11 December 2013 and numbered 28848;
It will be done through the Chemicals Registration System (KKS) Module by entering the Online ( http://online.cevre.gov.tr ) system of the Ministry of Environment (companies that have not received a password, please contact ).
Registrations in the S&E inventory of substances on the market (whether as a stand-alone substance or in a preparation) must be completed by 1 June 2015 .
Registrations in the S&E inventory of substances on the market (whether as a stand-alone substance or in a preparation) must be completed by 1 June 2015 .
Registrations in the S&E inventory of substances on the market (whether as a stand-alone substance or in a preparation) must be completed by 1 June 2015 .
The point where the Turkish CLP (SEA) differs is the 41st article of the regulation, according to this article, companies exporting to Turkey can fulfill their importers’ S&E reporting obligations through a designated Turkish Only Representative (Legal Representative) for the protection of CBI (Confidential Business Information).
Classification And Labeling Notification
In the 2nd article of the regulation, which is classified as harmful and classified as harmful and which causes the mixture to be classified as harmful and placed on the market in a mixture, either on its own or above the concentration limit values specified in this Regulation. There is an obligation to notify the specified substances.
In accordance with Article 41 of the Regulation, the manufacturer or importer or manufacturer or importer groups that place the above-mentioned substances on the market submit the following information in the format on the KKS notification system page in order to include the substance in the inventory of the Ministry of Environment.
In case of individual notification for the substance, the notifier responsible for placing on the market or, in case of joint notification, each importer or
manufacturer;
- Name, address, telephone number, fax number and e-mail address.
- Contact person.
- The address of the place of manufacture.
- Identity of the substance detailed in subparagraph (a) of the first paragraph of Article 39 of the Regulation.
- Classification of the substance in accordance with Article 15 of the Regulation.
- If the substance cannot be classified according to some hazard class or differentiation, information on whether this is due to the absence of data on the classification, the inconclusive data, or the inconclusive but insufficient data.
- Where appropriate, the special concentration limit values according to Article 12 or the M-Factor (coefficient) and justifications in accordance with the relevant sections of Annex 11 of the regulation.
- Additional hazard statement of the substance determined in accordance with Article 27, together with the labeling information specified in subparagraphs (ç), (d) and (e) of the first paragraph of article 19 of the regulation regarding the substance.
If it has been decided to change the classification and labeling of the substance in accordance with the review process specified in the first paragraph of Article 17 of the Regulation, the Competent Authority notifies it by updating the information in the first paragraph of the notification.
Within one month following the placing of the substances on the market, a notification is made in accordance with the first paragraph.
S&E Notifications are the first step in a long journey that is vital to KKDIK regulation. It is extremely important for the registration to be made in accordance with the KKDIK (Registration Permit Evaluation and Restriction of Chemicals) regulation, which is still in draft form and which is planned to come into force in 2015, and for the SIEF (Substance Information Exchange Forum) studies to be carried out in the same environment with companies that produce and/or import the same substance. Making your notifications correctly will give you a great advantage in the market in a long time. False notifications and steps taken without strategic planning may prevent your product from being offered for sale in medium and long-term cycles.
Remember, just like in the EU-REACH regulation, the era of ” NO INFORMATION, IT IS NOT IN THE MARKET ” has started in our country as well.
A right companion will provide you with very important benefits in this period, will prevent you from taking wrong steps, will provide a competitive advantage in the market, and will play an active role in your comfortable movement in international markets.
Our services related to SEA;
Doruk Sistem provides professional support in defining the TR-CLP (SEA) regulation obligations of companies exporting to Turkey and making inventory notifications to Turkish Authorized Institutions.
Doruk Sistem offers strategic consultancy and training package with full disclosure support to companies that want to complete their CLP (SEA) compliance requirements.
Turkish Chemistry Regulation Services;
Turkish Chemistry Regulation Services;
Doruksistem adaptation services:
- Only Representative services,
- Strategy and consultancy services,
- Evaluation of your company's regulatory obligations,
- Preparation of data requirements and documentation for notification (including, if necessary, determination of physicochemical, toxicological and eco-toxicological properties of substances)
- If necessary, notifications are made in a format in accordance with KKS,
- Contacting Turkish Authorities if necessary,
- Taking part as a 'Turkish Representative' on behalf of non-Turkish operations,
- Regulatory Compliance corporate training
- Preparation for KKDIK regulation and correct SIEF management studies