Turkey
SEA and KKDIK Regulations

How is GHS implemented
in Turkey?

Turkey adopts the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) through the Regulation on Classification, Labelling and Packaging of Substances and Mixtures (SEA), also known as Turkish CLP for taking the European Union CLP Regulation as a reference. Its objective is to protect human health, environment and allow the free movement of substances.

What is the SEA?

Turkey implements the second edition of the GHS through the SEA. Based on the European CLP, it considers Adaptations to Technical Progress (ATP). Its last update was on December 10, 2020 (RG Nº 31330) to incorporate the ATP 13.

The SEA entered into force on December 11, 2013 after its publication in the Resmî Gazete Nº 28848 and is mandatory for substances since June 1, 2015 and for mixtures since June 1, 2016.

The regulatory entity in charge of implementing GHS in Turkey is the Ministry of Environment, Urbanization and Climate Change (MoEUCC). In turn, the Regulation on Registration, Evaluation, Authorization and Restriction of Chemical Substances (KKDIK), also known as Turkish REACH, manages the notification and registration systems for companies that manufacture or import substances with a quantity greater than one ton per year.

The SEA applies to hazardous chemical products in general, although there are certain exceptions such as cosmetics, pesticides and detergents that are regulated under other legislation.

What are the most relevant points of SEA?

• Both the SDS and label must be in Turkish language.
• The FDS should have the standard format of 16 sections and should be drafted in accordance with the directives of the KKDIK:
  • It will be delivered free of charge with a date in paper or electronic format.
  • Must include the date of preparation.
  • It must be prepared by people certified for it, who must sign the SDS in section 16.
  • The registration and notification of chemical substances must include a legal entity in Turkey, so foreign companies are offered the possibility to appoint a Single Representative in the country to do so.
  • The SDS should be updated as soon as possible when new information on hazards, risks or the imposition of authorizations and restrictions becomes available. It should be given free of charge to recipients who have purchased this substance in the previous 12 months.
• The following hazard categories are excluded: Chemicals under pressure, all categories; Flammable gas, category 1A and 1B (including pyrophoric gases); Flammable liquids, category 4; Desensitized explosives, all categories; Acute toxicity, category 5; Skin corrosion/irritation, category 3; Serious eye damage/irritations, subcategories 2A and 2B; Aspiration hazard, category 2; Acute aquatic toxicity, categories 2 and 3.
• The minimum labelling requirements require: identity of the substance, name, address and telephone of the supplier, nominal volume on the packaging and where applicable: pictograms, warning words, H and P phrases, additional information.
  • The size of the label should be proportional to the size of the package.

What other chemical regulatory requirements apply in Turkey?

• The KKDIK came into force on December 23, 2017 to ensure the use of chemical substances by registering them with the MoEUCC. It is based on the REACH regulation of the European Union. The last amendment was made on December 23, 2023 (RG No. 32408). There is currently a calendar with different deadlines for registering substances that meet the following characteristics:
  • December 31, 2026:
    • substances manufactured or imported in a quantity exceeding 1000 tons per year.
    • substances manufactured or imported in a quantity exceeding 100 tons per year if the substance is classified as Aquatic Chronic or Acute, category 1.
    • substances manufactured or imported in a quantity exceeding 1 ton per year if the substance is classified as Carcinogenic, Mutagenic or Toxic for Reproduction (CMR), categories 1A and 1B.
    • December 31, 2028: substances manufactured or imported in a quantity between 100 and 1000 tons per year.
    • December 31, 2030: substances manufactured or imported in an amount between 1 and 100 tons per year.
  • Cosmetics are regulated under the Turkish Cosmetics Law No. 5324 published on March 24, 2005 and the Cosmetic Products Regulation No. 32184 published on May 8, 2023. The agency in charge of enforcing it is the Ministry of Health. In parallel, the Turkish Authority of Medicine and Medical Devices publishes a series of guides that help regulate all aspects related to cosmetic products in the country, including editions of the Regulation of Cosmetic Products to align them with European guidelines.
  • Pesticides are regulated under the Regulation on Classification, Packaging and Labeling of Plant Protection Products (Law No. 27885) issued on March 25, 2011. The entity in charge of ensuring its implementation is the Ministry of Agriculture and Forests, specifically its General Directorate of Food and Control (DGFC). This body establishes the need to register all products for plant protection in Turkey, and it is necessary to obtain a certificate on the commercial application of pesticides. There are three types of registrations depending on the nature of the pesticide, all collected and explained under Regulation No. 27885.
  • Detergents are regulated by the Detergent Regulation (RG Nº 30314) published on January 27, 2018, by the Ministry of Customs and Trade. This regulation resembles the European regulation (EC) 648/2004, the main difference is that in Turkey the notification of detergents has been eliminated. Other aspects such as the labeling, content of the SDS and technical data sheet, and how to prepare a technical dossier for detergents are specified.