KKDIK (Turkey REACH) Registration for Waste and Recovered Substances

What is the definition of waste?

Before giving information about the KKDİK (Turkey REACH) registration process for waste and recovered materials, it is necessary to define the word “waste”. According to the Turkish Regulation on General Principles Regarding Waste Management, the word “waste” covers substances created by an activity and disposed of or left in the environment. Substances within the scope of waste are included in one of the classes given in Annex 1 of the Turkish Regulation on General Principles Regarding Waste Management.

Is there a KKDIK (Turkey REACH) Registration obligation for waste?

According to the KKDIK Regulation, chemical registration is obligatory for substances, mixtures, and articles. Therefore, waste is not included within this scope. However, it should not be forgotten that wastes are not completely excluded from KKDIK. In accordance with KKDIK Regulation Annex 1 Section 5.2.2, the waste stage of the substances should also be taken into consideration. If substances or objects are subject to general use for special reasons; if there is a market or demand for them; if the technical requirements for specific purposes are met and are in compliance with the legislation and relevant standards, and if its use does not hurt the environment and human health, the substance is no longer be considered as waste. In other words, a recovery of the substance has taken place.

Recovered Substances and KKDIK (Turkey REACH) Regulation

KKDIK obligations also come into play when the waste status of substances or objects included in material groups such as paper, glass, metal, and polymer ceases and the recovery process is completed. As a result of recovery processes, materials that are not fully or partially considered as waste may come into view. And the exemption of these recovered substances depends on whether they have been registered before or not.

In this context, there are some obligations arising for companies that handle recovered materials. These companies must submit a Pre-MBDF for the substances used so that they can avoid problems that may arise when manufacturing the substance or placing it on the market. As with other substances, it is aimed to share information and facilitate the process for recovered substances, with the help of Pre-MBDF.

It can be said that recovered substances are subject to KKDIK registration in some cases, but to provide clarity on this issue, the substances must be identified and their properties such as type and impurity must be evaluated. KKDIK Annex 4 (Exemptions from the Obligation to Register In Accordance With Article 2(5)(a)(1)) and Annex 5 (Exemptions from the Obligation to Register In Accordance With Article 2(5)(a)(2)) should also be examined and the compliance of the substance with these criteria should be evaluated.

Before taking any steps in this process, the scope of the item in question should be determined accurately and an appropriate path should be followed. You may reach out to us for assistance with the topic and to gain further insights.