NEW STATEMENTS RELATED TO “1.7 SUPPLIERS” AND “13.1 CHEMICAL SAFETY REPORT” SECTIONS IN
KKDIK REGISTRATION DOSSIERS
As it is known, only representatives are required to add the Turkish importers of the overseas company they represent to the “1.7 Suppliers” section of their registration dossiers.
As a result of the evaluation of the opinions and suggestions from industry associations, associations and various companies by our Ministry, it has been deemed appropriate to remove the aforementioned information requirement from being obligatory.
In this context, although it is recommended that only representatives add the aforementioned information to the registration dossiers, there will be no deficiencies in the completeness checks to be carried out by our Ministry in the registration dossiers if they are not added.
The Only Representative’s registration dossier must contain all uses of the importers (now downstream users) covered by the registration. The only representative must keep an up-to-date list of the customers (importers) of the ‘non-Turkish manufacturer’ in the same supply chain and the tonnage covered for each of these customers, as well as the information on obtaining the latest update of the safety data sheet and submit the said information during the audits to be carried out by our Ministry.
In this regard, the information in the already published guides such as “Registration Guide”, “KKS User Guide” and in the “Frequently Asked Questions” field in the Chemicals Help Desk will be updated as soon as possible.
Some issues that only representatives and importers should pay attention to regarding the registration of chemicals are as follows. Detailed information can be found in the “Registration Guide” on the Chemicals Helpdesk.
Importers should obtain confirmation from the ‘non-Turkish manufacturer’ whether an only representative has been appointed. In addition, it is highly recommended that they obtain written confirmation from the only representative that the tonnage and usage imported are indeed covered by the registration submitted by the only representative. This will provide the importer with a point of contact to report their use if they are considered downstream users, and will also give the importer clear documentation that their imports are indeed covered by the registration of the only representative. In addition, the importer is required to obtain sufficient information from the ‘non-Turkish manufacturer’ and/or the only representative to fulfill the obligation to compile the safety data sheet, where relevant. The importer in Turkey should be able to document which imports are included in the scope of the registration to be made by the only representative, if requested by our Ministry.
13.1 Chemical Safety Report
It has been stated that the Chemical Safety Reports, which are required to be submitted in the registration files of chemicals of 10 tons or more per year, bring additional costs due to the long duration of translation and the registration period will expire at the end of this year.
However, registrants who prefer to upload the Chemical Safety Report in English are required to attach the translated version to the registration dossier to include the uses, exposure scenarios and risk management measures in Turkey within 1 (one) year at the latest as of 31 December 2023, which is the registration deadline.
On the other hand, it is still necessary to fill in all the fields in the system regarding the “Comprehensive Study Summaries” and “Study Summaries” to be submitted in the registration dossier, in Turkish.
***REGISTER YOUR CHEMICALS UNDER THE KKDIK REGULATION UNTIL 1.1.2024. THE MANUFACTURING AND/OR IMPORT OF SUBSTANCES THAT ARE NOT REGISTERED IN THE CHEMICAL REGISTRATION SYSTEM WILL NOT BE ALLOWED UNTIL 1.1.2024.***