Understanding the Recent Amendments to KKDIK

Understanding the Recent Amendments to KKDIK

On December 23, 2023, a significant shift in Turkey's chemical regulatory landscape unfolded as the Ministry of Environment, Urbanization, and Climate Change introduced a series of amendments to the "Kimyasalların Kaydı, Değerlendirilmesi, İzni ve Kısıtlanması" (KKDIK) regulation. Published in the Official Gazette under the number 32408, these changes mark a substantial evolution in the framework governing the registration, evaluation, authorization, and restriction of chemicals in the country.

Background

The KKDIK regulation, initially published on June 23, 2017, outlined guidelines for the registration, evaluation, permission, and restriction of chemicals. This legislation was designed to ensure the safe management of chemicals within Turkey, aligning with international standards and best practices. However, recognizing the dynamic nature of the chemical industry, the Turkish government deemed it necessary to revisit and enhance certain aspects of the regulation.

Key Amendments

The recent amendments to the KKDIK regulation encompass several crucial modifications. Here are some of the notable changes introduced:

  • 1. Expansion of Scope (Article 1)

  • The second paragraph of Article 2 of the original KKDIK regulation is revised to include substances imported by the Central Bank of the Republic of Turkey and those manufactured or imported for defense purposes.

  • 2. Collaborative Data Sharing (Article 2, Article 5)

  • A new provision (Article 5) emphasizes collaboration between the Turkey Chambers and Commodity Exchanges Union, relevant institutions, and organizations. This collaboration is intended to facilitate a joint registration process, including data and cost-sharing, as outlined by the Ministry.

  • 3. Deadline Extensions (Article 3, Article 7)

  • The deadlines mentioned in Articles 24, 25 and 39 of the original regulation are extended significantly. Notably, the registration deadline for substances meeting specific tonnage and hazard criteria is pushed to December 31, 2030 (annual quantity equal to or greater than 1 ton). For substances imported or manufactured in an annual quantity equal to or greater than 100 tons, the registration deadline is 12/31/2028.

  • 4. Provisions for Temporary Measures (Article 6, Article 8)

  • The regulation introduces provisions for temporary measures, enabling the preparation of registration files after the specified deadlines, with a focus on meeting information requirements and test proposals.

  • 5. Guidelines for Data Recording (Article 65/A)

  • A new article, 65/A, emphasizes that the procedures and principles for data recording and data acquisition within the scope of the regulation will be determined by the Ministry.

Implications and Future Outlook

These amendments signify a proactive approach by the Turkish government towards strengthening chemical regulation and ensuring the safety of both human health and the environment. By extending deadlines and refining procedural aspects, the government aims to strike a balance between regulatory compliance and industry needs.

For businesses operating within the chemical sector, these changes necessitate a thorough review of their current practices and an alignment with the updated regulatory requirements. Moreover, ongoing vigilance and adaptability will be crucial as further developments in chemical legislation unfold.