What is KKDIK Third Party Representation?
The Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals entered into force after being published on 23 June 17. The main purpose of the regulation is to produce alternatives for the evaluation of the harmfulness of substances by considering the protection of human and environmental health at the highest level.
If the substances subject to the regulation are found in their own form, mixture or articles are not registered according to the provisions of the KKDIK Regulation, there will be great sanctions for their manufacturing and placing on the market. To avoid these sanctions and to continue production, it is necessary to register the chemicals based on substances. The registrations will be made over the Chemical Registration System opened on the Integrated Environmental Information System of the Ministry of Environment and Urbanization, which is the enforcer of this regulation. Manufacturers, importers and downstream users who apply for registration through this system will be accepted as participants of the Pre-Substance Information Exchange Forum (SIEF). The aim of each SIEF is to avoid duplication of studies and tests and to agree on classification/labeling differences. In the announcements published by the Ministry, it has been announced that pre-notification can be made until 2021 and that they will not demand any fees from these notifications. These registrations will take place as a Pre-Substance Information Exchange Forum (pre-SIEF). In the notifications made through the integrated system of the Ministry of Environment and Urbanization, the notifying parties can see each other. Third party representation comes into play at this point. Companies will ensure the confidentiality of their companies by making agreements with third parties that their names are not displayed in their pre-SIEFs within the framework of “know-how” (information confidentiality).
The main duty of the Third Party Representatives
The main duty of the Third Party Representatives is to register the substances of the companies they represent and to represent the companies in the consortiums to be formed. During the registration process, when the parent company enters the joint registration process with other companies, the representative appointed as a third party will appear and registration will be carried out on behalf of the representative. During the joint registration process, other companies will not be able to see the main company that appointed a third party representative. Only the assignment made by the ministry will be viewable.
Third Party Representation Service
- Pre-Registration (Pre-SIEF) of Domestic Manufacturer, Importer, Downstream User items.
- Following the activities before the SEIF (Substance Information Exchange Forum) and informing the domestic producer on any possible issue.
- Conducting all necessary communication with consortiums when established.
- The producer submits the 3-year amounts to the KKS System of the Ministry of Environment and Urbanization.
- Preparation of registration dossiers before the registration date, December 31, 2023.
- Determining the required test reports while preparing the Technical File.
- Monitoring the necessary activities while preparing the Technical File
- Preparation of Chemical Safety Reports.