On 23 December 2023, the Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) announced the updated Regulation Amending the Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals (Notice No. 32408, known as KKDIK, Turkey REACH) which specifies the delayed deadline of chemical registrations. The purpose of this Notice is to clarify the phase-in registration deadlines for chemicals under different tonnages and hazard characteristics.
In November 2023, MoEUCC issued the Draft Revision of the Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals (KKDIK). The Draft proposes that the deadlines of the KKDIK Regulation will be gradually extended based on registration tonnage and hazard characteristics of chemical substances.
In this Draft Revision, the registration deadline for chemicals produced or imported to Turkey is postponed in the following:
- The commencement date in Article 24 (Inquiry) and the expiry date of in Article 25 (SIEF formation) of the Regulation is extended from "December 31, 2023" to "December 31, 2030";
- The termination date of SIEF is extended from "December 31, 2025" to "December 31, 2025"; and
- The deadline for pre-registration is removed and the provision "up to December 31, 2020" in the provisional Article 1 of the Regulation is changed to "Deadline specified in the procedures and principles published by the MoEUCC";
- The provision of Paragraph 1, Article 2 of the Provisional Regulation is amended as follows:
Substances meet the following conditions shall be registered before December 31, 2026;
- Substances manufactured or imported in quantities≥1,000 tpa;
- Substances manufactured or imported in quantities≥100 tpa and substances classified as Aquatic Acute 1 and/or Aquatic Chronic 1 (H400, H410); and
- Substances manufactured or imported in quantities ≥1 tpa and substances are classified as Category 1A or 1B of carcinogenicity, mutagenicity and/or toxic to the reproductive system, in accordance with the Regulation on Classification, Labeling and Packaging of Substances and Mixtures.
- Without prejudice to the deadline given in paragraph (a), substances manufactured or imported in quantities≥100 tpa shall be registered before December 31, 2028.
- Without prejudice to the periods given in paragraphs (a) and (b), substances manufactured or imported in quantities ≥1 t/y shall be registered before December 31, 2030.
The Authorisation list, the candidate list and the assessment list shall be commenced from 31 December 2026.
Under Turkey KKDIK, many substances are not registered because entities do not have a lead registrant (LR) or LR does not complete substance registration within the original deadline, which may prevent enterprises from exporting their chemical products to Turkey. The extension of the registration deadline indeed reduces registration costs and alleviates pressures on companies. Companies can conduct relevant activities with pre-registration number before the deadline. Enterprises without a pre-registration number may apply for pre-registration through OR or importers in Turkey.
