KKDIK was published on 23 Jun. 2017 by Ministry of Environment and Urbanization of Turkish Republic and formally came into effect on 23 Dec. 2017. The regulation shares many similarities with EU REACH, thus it is also called Turkey REACH.
Scope of Registration
Substances in quantities of one ton or more per year manufactured in or imported into Turkey;
Substances in mixtures in quantities of one ton or more per year manufactured in or imported into Turkey;
Substances in articles manufactured in or imported into Turkey which are intended to be released under normal or reasonably foreseeable conditions of use and the quantity totals 1 ton per year or more.
Who shall Complete KKDIK Registration?
Turkey manufacturers and importers of substances (including substances in mixtures);
Turkey manufacturers and importers of articles (intended release);
Non-Turkey manufacturers of substances, mixtures and articles must perform the registration obligations under KKDIK through only representatives (OR) based in Turkey.
Timeline for Registration/Pre-registration
KKDIK Registration can be divided into two steps:
Step 1: Pre-registration
Step 2: Registration.
Details are as follows:
KKDIK was officially published on 23 Jul. 2017 and came into effect on 23 Dec. 2017. Preregistration obligations apply to substances manufactured or imported in quantities of one tonne or more per year per manufacturer or importer. The deadline of pre-registration is 31 Dec. 2020.
The registration grace period is between 1 Jan. 2021 and 31 Dec. 2023. Enterprises who have pre-registered their substances can use the pre-registration number for manufacturing or importing during the period;
From 1 Jan. 2024, registration must be done before substances are manufactured or imported;
Information Required for Pre-registration
Substance information (such as substance name, CAS No., EC No., substance structure, etc)
On-site isolated intermediates under strictly controlled conditions
Existing data only
Transported isolated intermediates under strictly controlled conditions
Existing data only
KKDIK Annex VII
Registration of regular substances
A) 1-10t/y standard registration, all data specified in Annex VII;
B) 1-10t/y, The information on physicochemical properties specified in Annex VII, for substances which do not meet either of the criteria specified in Annex 3;
KKDIK Annex VII+VIII
KKDIK Annex VII+VIII+IX
KKDIK Annex VII+VIII+IX+X
Note: for >=10t/y regular registration, a chemical safety report (CSR) is needed as well.
1. Intermediates can be divided into 3 categories: Non-isolated intermediates, on-site isolated intermediates, transported isolated intermediates.
Non-isolated intermediates: an intermediate that during synthesis is not intentionally removed (except for sampling) from the equipment in which the synthesis takes place.
On-site isolated intermediate: an intermediate not meeting the criteria of a non-isolated intermediate and where the manufacture of the intermediate and the synthesis of (an)other substance(s) from that intermediate take place on the same site, operated by one or more legal entities;
Transported isolated intermediates: an intermediate not meeting the criteria of a non-isolated intermediate and transported between or supplied to other sites;
Polymers: Similar to EU REACH, polymers is exempted from registration under KKDIK. However, monomers or other reactants of polymers shall also be registered when they meet certain conditions.
Definition of polymer: a substance consisting of molecules characterised by the sequence of one or more types of monomer units, distributed over a range of molecular weights wherein differences in the molecular weight are primarily attributable to differences in the number of monomer units and comprises the following:
1) A simple weight majority of molecules containing at least three monomer units which are covalently bound to at least one other monomer unit or other reactant; and
2) Less than a simple weight majority of molecules of the same molecular weight.
Monomer: a substance which is capable of forming covalent bonds with a sequence of additional like or unlike molecules under the conditions of the relevant polymer-forming reaction used for the particular process;
Polymers can exempt from registration. But if their monomers and other reactants fulfill the following conditions, registration is required:
a) The polymer consists of 2 % weight by weight (w/w) or more of such monomer substance(s) or other substance(s) in the form of monomeric units and chemically bound substance(s);
b) The total quantity of such monomer substance(s) or other substance(s) makes up one ton or more per year.
KKDIK Regulatory Compliance Consulting and Training;
KKDIK OR Service;
Turkey CLP Regulation Regulatory Compliance Consulting and Training;
Turkey CLP Regulation OR Service;
C&L Notification under Turkey CLP Regulation;
Turkish SDS and Labeling Preparation;