According to the KKDIK (Turkey REACH) Regulation, if there is more than one registrant for the same substance, data sharing (and joint submission) is obligatory. Chemleg carries out the Data Sharing Management of the substances for which it undertakes the task of the lead registrant or service consultant. This includes communication with joint registration members, data sharing agreements, LoA (Letter of Access) sales, and calculation, exchange, and tracking of all process-related costs.
Chemleg uses KKDIKPro software in order to carry out this management task in an organized and effective way. This software is a common platform used by various lead registrants and its purpose is to provide a fair and transparent process to joint registration members. The features that this management system provides to its users can be examined below:
The costs spent to obtain data on the relevant substance under EU REACH are used as a calculation coefficient for the LoA fees to be charged to the joint registration members, depending on the tonnage, within the scope of KKDIK. Thanks to this feature, a specific calculation has been developed for each substance and a fair process is thus provided to the co-registrants. By sharing the document prepared on the calculation of data costs with the members through the system, full compliance with the transparency principle of the regulation is also ensured.
After each completed LoA purchase procedure, the system automatically calculates the current LoA fee for new members who wish to participate in the joint registration. In parallel, each new after-sale reimbursement amount for the joint registration members who already purchased the LoA is also calculated automatically by the system.
Joint registration members who wish to purchase LoA may be offered two different purchase options. In the first option, the data access process is completed after the payment and documentation process on the substance for which the purchase request is created with the direct purchase option. The second option is the Pool option, which can be identified as a collective registration system. Members who wish to complete the registration process of the relevant substance may join the pool until the specified date and may complete their LoA purchases at lower prices on the pool closing date.
Joint registration members are notified by automatic e-mails during each transaction in the LoA purchase process of the relevant substance. For instance, notifications regarding new substance additions to the lists, request confirmations, reimbursement information, etc. are automatically sent to the joint registration members by the system.
Joint registration members can access all documents related to substances and purchases from their user pages. Documents such as substance sameness documents, classification information, bank account information for payment, and cost calculation methodology can be listed among the examples.
Agreements regarding the management style to be adopted by the lead registrant in the registration process of the relevant substance (data sharing agreement, SIEF agreement, or joint submission agreement) are presented for the control of joint registration members. From their user page, joint registration members can easily download and review the relevant agreements and re-upload the signed documents to the system.
Through the system, joint registration members can forward the payment receipt of the substance they wish to purchase LoA to the lead registrant, and they can also track the reimbursements to be made to them in the specified periods.
KKDIKPro software serves not only as a system for LoA purchases but also as a data market that provides access to the Chemical Safety Report (CSR) and Safety Data Sheet (SDS) of the relevant substance or substances. Soon, the tonnage band update option will also be active for the relevant substances that the tonnage range is compatible with.
To view the software, you can visit kkdikpro.com and if you have any questions, you can email [email protected].
