Turkish REACH (KKDIK in its Turkish abbreviation) requires that all chemical products manufactured in Turkey or imported into the country in a quantity of one ton or more have a uniform registration deadline of December 2023. A failure to comply means that a company faces the threat of blocked imports.
The registration phase has been ongoing since March 2021, but the registration process has been anything but expeditious. Only one hundred registrations had been submitted by the end of 2021. Two principal reasons are responsible for laggard registration.
First, participants are wrangling hard over the rights to data access and the cost of the rights. The costs are set in a letter of access and due when several companies, rather than individual firms, jointly submit chemical registrations. Many companies, especially small and midsize ones, have so far refused to pay the fees demanded by the owners of the data, which slows the registration process.
Second, many companies have criticized what they consider clumsy collaboration with the Ministry of Environment, Urbanization, and Climate Change (MoEUCC), which is responsible for the registrations. The malaise already begins with the payment of registration fees. So far, the ministry does not accept online payments; instead, company representatives are required to pay the fees via cash at a bank branch.
Many companies have also noted poor communication with the Ministry as an issue. For example, the Ministry published only two brief announcements on its Web site during all of 2021.
The lack of transparency has also been criticized. The MoEUCC announced that 160,000 chemical substances have been registered so far, but which of them were KKDIK preregistrations and which were notifications of hazardous substances according to the Turkish CLP regulation (SEA) remain unclear.
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