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The years 2020Â to 2023Â have been key strategic years for many companies that are producing, importing or using chemicals in Turkey. However, the implementation of the high impact KKDIK (Turkish REACH)Â legislation (and in parallel SEA)Â requires companies to prepare and manage a huge numbers of activities until the deadline of 31 Dec. 2020 for pre-registration and 31 Dec. 2023 for registration.
LISAM services for KKDIK, SEA (Turkish CLP) and related regulations
Lisam System is the leader consultant company working in KKDIK consortia and SIEF joint registration activities and communications first in Turkey.
On the other hand, we can prepare registration dossiers (data, hazard assessments, risk assessments) in accordance with the complete requirements of KKDIK with all our certified experts trained by the ministry registered trainers.
Assuring a detailed answer covering details on delivering time need to consolidate registration data, dossier information, compliance translations and rates for all the different tonnage bands, update registration, simplified and exemption notification arrangements will take time in accordance with your substances, classifications, and tonnage bands, substance types. Â
But you can be ensure that we can plan and present all detailed information to you whenever you want including your detailed questions about KKDIK.
We have capability to support you by preparing the CRS (Online Chemical Registration System of MoEU) dossiers in Turkish with crossword translations of your current IUCLID (5 or 6) dossiers if you already have a REACH registration dossier for a substance registered in the EU.
Are you affected by KKDIK TURKISH REACH?
If you manufacture chemical substances or import them from outside Turkey above 1Â TPA, you may have registration obligations under KKDIK. Additionally, if you manufacture or import a mixture or article, it may contain substances that need to be registered individually.
You should start preparing for the KKDIK registrations by analysing the company’s portfolio and inventory from the KKDIK perspective and creating a plan for managing the KKDIK registrations.
KKDIK (TURKISH REACH) Registrations
As Lisam, we offer a long-term legal presence, client representation and perform all the mandatory continuous data collection tasks required.
As Only Representative, we look out of the substance identification, best registration strategy, a radical evaluation of existing data, the identification of knowledge gaps and a precisely fitting proposal of testing strategies with due reference to scientific also as economic aspects so as to shut these gaps.
We assist our clients with an entire KKDIK chemical safety report prepared by the certified Chemical Assessment Specialists (KKDIK Annex XVIII) and necessary collection of data within the supply chain, handling of third-party access rights and financial transactions, completing the technical dossier and submitting it to Ministry of Environment as only representative.
We can offer a service to facilitate consortia/SIEF joint registration activities (e.g. data/cost sharing, consortium, monitoring, registration, liaising fees) also .
Lisam provides support for consortia with the legal staff drafting the required documentation to urge client’s consortium running.Â
We ensure that the companies fulfil on time the KKDIK obligations and also facilitate communication and exchange information within the SIEF and within the members of the consortium.
LISAM services for KKDIK, SEA (Turkish CLP) and related regulations
On-call access to KKDÄ°K Turkish REACH experts for support of KKDÄ°K registration related questions,
Determination of the company role and responsibilities under KKDIK
Managing the full process for substances under the scope of KKDIK
Determination of chemical characterization of the substances
To be done pre-registration
Participation in the SIEF, including contact and coordination with SIEF members,
Data exchange and evaluation,
Join and follow-up all activities in pre-SIEF and SIEF
Negotiation with SIEF and Consortium members,
Following up consortium activities
Authorized negotiations with Turkish Ministry of Environment,
Notification to the MoEU of quantities of products manufactured/imported and related risk assessments
Collection and submission of technical dossiers,
Data management and data-gap analysis
Translations, preparation and compilation of registration dossier
Submission of registration applications,
CSR authoring
Uploading registration dossier to KKS by the chemical assessment specialists
Creation and submission of KKDÄ°K compliant Safety Data Sheets (SDS),
High-level discussions about risk assessments and use of information,
Communication concerning substances to downstream users,
Classification of substances/mixtures supplied to the market
Labelling and packaging of harmful substances/ mixtures
Determination of label and packaging dimensions of hazardous substances and mixtures.
Notification of hazardous substances to C&L (SEA) inventory through KKS
Follow up the updated information of the substances
Preparation of Safety Data Sheets
Extended-SDS compilation services,
Establishing of the substance inventory list under Annex-17