Regulation Under KKDIK: Important Pre-SIEF and Restriction Process
The "Regulation on the Registration, Evaluation, Authorization, and Restriction of Chemicals," which is an adaptation of the European Union REACH Regulation, was published by the Ministry of Environment and Urbanization of the Republic of Turkey on 23/06/2017.
The regulation has entered into force with some new provisions, including Permit, Evaluation, and Registration processes. Additionally, the KKDIK Regulation has repealed some existing regulations in the past and expanded their scopes with additional conditions.
The sole provision that came into effect on the day the KKDIK Regulation was published is the revocation of the Regulation on the Inventory and Control of Chemicals, numbered 27092. Some provisions, however, came into effect on 23/12/2017. The regulation's provisions will continue to enter into force gradually until 31/12/2023.
Article 66 – According to (1) ç), the Pre-Pre-registration process came into effect on 23/12/2017. This process, referred to as Pre-Substance Information Exchange Forum (Pre-SIEF) in the REACH Regulation, and which can be considered as a preparatory stage before the registration process, is referred to as Pre-Substance Information Exchange Forum (Pre-SIEF) in the KKDIK Regulation. Those who will carry out the Pre-SIEF notification will be potential registrants of the Substance Information Exchange Forum.
The Pre-Pre-registration (Pre-SIEF) process covers the period from 23/12/2017 to 31/12/2020.
There is an obligation for Pre-Registration/Registration for substances manufactured or imported in quantities of one ton or more per year, either on their own or in mixtures.
All actors who will Register under KKDIK must submit the Pre-SIEF to the Ministry via the Chemical Registration System on the Ministry's website by 31/12/2020.
Another important issue that came into effect on the same date is the restricted substance/chemical group lists defined in the "Restrictions on the Manufacture, Placing on the Market, and Use of Certain Hazardous Substances, Mixtures, and Articles (Annex 17)." With the entry into force of the regulation, the Regulation on the Restriction and Prohibition of Hazardous Substances and Mixtures, numbered 27092, was repealed. The content of the Regulation numbered 27092 contained only 20 substances/groups. Eighteen of the 20 entries have been directly included in the KKDIK Annex 17 scope. Since there are additional entries in the KKDIK Annex 17 entries compared to the old Restriction Regulation, importers, manufacturers, or downstream users need to take immediate action.
In KKDIK Annex 17, there are 66 entry lines, but lines 33, 39, 42, and 44 are not included in KKDIK Annex 17. The actual number of lines is 62. Additionally, there are 10 sub-attachments to KKDIK Annex 17, detailing restrictions based on classification and chemical groups. The use of some chemicals on restriction lists is either prohibited on their own, in mixtures, or in articles, or their use is permitted only at certain concentrations and excluding certain industrial sectors. Since the Regulation KKDIK Annex 17 is related to substances and substance groups either on their own, in mixtures, or in articles, it affects not only manufacturers and importers but also the entire chemical industry.
Entries in Annex 17 are found in three different ways: through EC and CAS numbers, chemical group names, or classification-based. You can find the critical implementation dates of entries and some sample Annex 17 entries below;
KKDIK Annex 17 list enters into force on five different dates. You can see the entry numbers of 38 substances/chemical groups that entered into force on 23/12/2017 below;
1- 27 (inclusive), 43, 46b, 47(2,3,5,6, and .7 paragraphs), 50, 51a, 51b, 51c,52a, 52b, 52c, 56, 59, 61, 63,64
2- 20 substances/chemical group entry numbers that entered into force on 31/12/2018;
28,29,30,31,32,34,35,36,37,38,40,41,45,48,49,54,55,57,58,60
3- 20 substances/chemical group entry number that entered into force on 31/12/2019;
Entry number 62
4- 3 substances/chemical group entry numbers that entered into force on 31.12.2021;
46a, 47. Only paragraphs 1 and 4 of the entry and 65
5- 1 substance/chemical group entry number that entered into force on 31.12.2022
Entry number 66
Sample Annex 17 entries;
Chloroethylene (vinyl chloride) - Chloroethylene cannot be used as a propellant in aerosols. Aerosol sprays containing this substance as a propellant cannot be placed on the market.
Toluene - Toluene cannot be used in adhesive and spray paints planned for retail sale as a substance or in mixtures at concentrations equal to or greater than 0.1% by weight or placed on the market.