Turkish REACH: Closing Consultation and Corporate Concerns

Until the end of January, representatives of affected industries can comment on the current draft of the planned Turkish chemicals law (KKDIK), before the Ministry of Environment and Urbanisation(MoEU) publishes the law at the end of March. The current registration deadline is December 31, 2022; preregistration should be complete by the end of 2019.

Industry objections primarily involve the costs of registration, which many of the mostly small and midsize companies affected by the law are almost impossible to pay. That’s why the industry representatives have asked the ministry to support the companies appropriately.

The annexes to the regulation are also unclear. Right now, the substances in Annex 17, which have limitations, agree with the list given in EU REACH, but the list has not yet been updated. However, no consensus yet exists about of the substances given in Annex 14 that are subject to approval.

The planned Annex 18, which does not appear in the EU regulation, might be the Achilles’ tendon of KKDIK. The annex defines the roles and qualifications that an expert on processing the approvals and notifications must absolutely have. Industry representatives fear that only very few people can fill the required profile, which requires 10 years of professional experience. The resulting personnel bottleneck means that the processing times have been lengthened. Hiring of foreign experts might be a possible solution.

Do you operate in the Turkish market? If so, please attend our Customer Day on May 11, 2017 (only in German). The new chemicals law in Turkey will be the topic. The CEO of our Turkish partner CRAD, Melih Babayigit, will offer first-hand information. Please contact us at sds@kft.de.