The years 2020 to 2023 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) legislation (and in parallel SEA) 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.

Are you affected by KKDIK TURKISH REACH?

If you manufacture chemical substances or import them from outside Turkey above 1 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. 
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 KKDİK Turkish REACH experts for support of KKDİK 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 KKDİK 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