In a significant development for the Turkish chemical industry and global chemical companies operating in Turkey, the much-anticipated amendment to the KKDIK Regulation has been officially published in the Official Gazette dated 23 December 2023. This amendment, officially titled "Regulation Amending the Regulation on the Registration, Evaluation, Authorization, and Restriction of Chemicals," marks a pivotal change in the regulatory landscape for chemicals in Turkey.
Background
The original KKDIK Regulation, akin to the EU's REACH regulation, sets forth requirements for the registration, evaluation, authorization, and restriction of chemicals in Turkey. The recent amendment follows the Ministry of Environment, Urbanization and Climate Change (MoEUCC)’s publication of a draft in November 2023, which proposed extensions to the registration periods and outlined the process for joint registration. This draft brought significant attention from the chemical industry, as it impacted the compliance timelines for entities under the KKDIK regulation.
Key Amendments and Implications
The published amendment officially extends the registration deadlines for substances manufactured in or imported into Turkey. These are categorised based on tonnage and hazard classification:
- December 31, 2026: For substances manufactured or imported at ≥1,000 tonnes per annum (t/a), substances classified as Aquatic Acute 1 and Aquatic Chronic 1 (H400, H410) at ≥100 t/a, and CMR substances (Category 1A and 1B) at ≥1 t/a.
- December 31, 2028: For substances in the range of 100 – 1,000 t/a.
- December 31, 2030: For substances in the range of 1 – 100 t/a.
These changes provide additional time for companies to comply with the KKDIK regulations, alleviating immediate pressures and allowing for more thorough preparation and implementation of the necessary measures.
Action Steps for Stakeholders
Entities affected by these regulations should take the following steps to ensure compliance:
Review and Update Compliance Plans: Companies should reassess their current compliance strategies in light of the new deadlines, ensuring that all necessary measures are taken well in advance.
Engage in Joint Registration Processes: The amendment encourages collaborative efforts among companies for registration processes, which can lead to cost and resource efficiencies.
Monitor Further Developments: Stay informed about any additional guidance or procedural details that may be issued by the MoEUCC.
The amendment to the KKDIK regulation provides a much-needed respite and clarity for stakeholders in the Turkish chemical industry. It is a positive step towards ensuring both regulatory compliance and the sustainable management of chemical substances in Turkey. Stakeholders are advised to actively engage in understanding these changes and adapting their strategies accordingly for a smooth transition to compliance with the amended regulation.
