Definition of Substances and Determination of Responsible Parties within the scope of KKDIK (Turkish REACH)

The purpose of KKDIK (Turkish REACH) is to bring chemicals under control in some way with the intent of ensure the protection of living things and the environment, notably for humans. Chemicals produced by natural or unnatural ways encounter in all areas of our life. The control mechanism is organized in such a way that chemical substances are registered, permitted or restricted after the evaluation of the chemicals. Determination and management of the requirements for the related procedures for KKDIK (Turkish REACH) Regulation are provided by the Ministry of Environment and Urbanization.

The chemicals to be assessed within the scope of the KKDIK (Turkish REACH) Regulation are grouped directly into the substance itself, in the mixture or in the article. The definitions of these groups are briefly described as follows;

The Definition of Substance within the scope of KKDIK (Turkish REACH): Chemical elements and compounds formed by this chemical element are defined as substances. The production of the substance can be realized in natural or unnatural ways. As the substances, themselves are assessed within the scope of the KKDIK (Turkish REACH) Regulation, the impurities which occur during the production of the substances and which are not added for a specific purpose of production are also considered as substances within the scope of the KKDIK (Turkish REACH) Regulation. Solvents that may be separated from the substance are outside the scope of the KKDIK (Turkish REACH) Regulation.

The Definition of Mixture within the scope of KKDIK (Turkish REACH): Structures formed by combining two or more substances with physical means are defined as mixtures.The evaluation within the scope of the KKDIK (Turkish REACH) Regulation, is not for the mixture, it will be for the presence substances in the mixture. Alloys are also considered as a mixture within the scope of KKDIK (Turkish REACH).

The Definition of Article within the scope of KKDIK (Turkish REACH): Articles are objects shaped or designed intended for use. In this process, it is important that the object is produced in accordance with its function rather than its chemical structure. Within the scope of KKDIK (Turkish REACH), for objects that are in the category of articles, the use and use rate of "Substances Very High Concern (SVHC)" substances should be evaluated. However, if there is a substance in the article intended to be released, this substance in the article has a registration obligation under the KKDIK (Turkish REACH) Regulation.

Parties with Responsibilities under the KKDIK (Turkish REACH) Regulation:

The roles of the parties that have or will might have responsibilities, within the scope of the KKDIK (Turkish REACH) Regulation should be well defined. In this context, the definitions of the parties that have or might have responsibilities, can be briefly summarized as follows;

Manufacturer: It is a natural or legal entity settled in Turkey that manufactures the substance in Turkey.

Importer: It is a natural or legal entity settled in Turkey that supplies substance from a country other than Turkey in order to supply to the Turkey market.

Only Representative: It is a natural or legal entity settled in Turkey which has been appointed by the manufacturer, formulator or article producer outside Turkey, with the intention of fulfilling the responsibilities of manufacturer, formulator or article producer behalf.The Only Representative is obliged to ensure that the chemicals, under its responsibility, are in accordance with the provisions required in Turkey. It can be assigned within the scope of KKDIK (Turkish REACH) by appointment by manufacturer, formulator or article producer outside Turkey.

Downstream Users: It is a natural or legal entity established in Turkey that does not manufacture or import the material but supplies it for its own industrial purposes.Sub-users are not distributors or consumers. As mentioned, it is the party that uses the substance for its own professional purposes, directly or in mixture, for formulation, storage, filling of containers, mixing, production of articles and the like.

Article Producers: These are real or legal entities who manufacture or provide the formation of the article settled in Turkey.

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