A common misconception companies have is that they can wait until the 2020 deadline to pre-register while continuing to place chemicals on the Turkish market. However, the Ministry of Environment and Urbanisation’s (MoEU) Guidance on Registration states that potential producers or importers of a substance manufactured or imported at over one tonne a year must submit a pre-registration to continue to manufacture or import.
The repeal of the CICR (Turkey’s previous by-law on the inventory and control of chemicals) and the closure of it’s online notification system on 23 June 2017 have resulted in companies being unable to demonstrate compliance with the Turkish chemicals regulations after that date and therefore being considered non-compliant with any chemical regulation.
Turkey’s CLP regulation (SEA) was published long before the KKDIK and the fact that the two regulations are now joined on one single online web portal intensifies the necessity to review compliance and adapt accordingly. The requirement for notification of substances under SEA goes back to 2015 and any new substance must be notified to the MoEU through KKS (chemicals registration system) within a month of being placed on the market. Also, as pre-registration is the first step to complete before SEA notification, companies need to pay special attention because this compliance replication can create confusion. It should be noted that the KKS is only accessible to Turkish legal entities that have gained permission from the MoEU.
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