Lisam Systems provides full support to complete this first major step in KKDIK Turkish-REACH compliance by defining your responsibilities for KKDIK, on a company-wide level, and for each substance under scope. Lisam Turkey will also collect and organize all of the required data, create the necessary KKDIK pre-registration information packages for your substances and we submit the pre-registration packages to the Ministry of Environment online system. (KKS)

Lisam’s KKDIK Turkish REACH pre-registration service includes:

• Creation of compliance strategy and decision tree,

• Collection of substance identification information,

• Creation of Substance KKDIK Pre-registration Information Packages (SPRIP)

• Submission of KKDIK pre-registration packages to Ministry of Environment,

• Expert KKDIK Turkish REACH consulting and on-call support for the duration of Pre-registration, (pre-SIEF)

• Support non-EU companies through our comprehensive KKDIK Turkish REACH Only Representative service

• Onsite and web-based educational presentations

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Lisam Systems’s KKDIK pre-registration services ensures companies:

• Understand your KKDIK Turkish REACH responsibilities

• Pre-register all substance, (pre-SIEF)

• See as little disruption to Turkey sales as possible

May KKDIK substances which have been pre-registered that are manufactured or imported before the relevant registration deadline be placed on Turkish market after this deadline without submitting a registration?

KKDIK enjoins registration liabilities only on manufacturers or importers (and, in particular cases, on producers or importers of articles). 

The registration responsibility does not implement to downstream users or distributers. 

Therefore, the registration obligation does not carry out to you if you have:

• manufactured or imported KKDIK pre-registered substances before the registration finishing time; and

• completely stopped such activities and only used the substances and/or supplied them after that.

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For example, importers for whom the last party of the substance was imported on 30 Dec 2023, at the latest, may continue to use and/or supply that substance after the deadline without a registration, without time limit.

If you have not stopped your activities before the registration deadline, you have an obligation to register the substance corresponding to KKDIK Turkish REACH.

If you are a downstream user (or other actor in the supply chain) not submit to registration obligations, you can continue to use without time limits and / or supply amounts of the substance produced or imported before the registration deadline.