It is important to understand whether your substances or products must be registered under KKDIK in Turkey. Read this short article to find out more about specific requirements. 

Substances

A substance is defined as a chemical element and its compound obtained by a manufacturing process or in its natural state. Individual substances have to be registered, regardless of whether they are on their own or in a mixture, if they are manufactured or imported in Turkey at or above 1 tonne per year. 

Substances in Mixtures

A mixture is defined as “a mixture or solution composed of two or more substances”. Many chemical products are mixtures of several substances, therefore it is necessary to understand the composition of these mixtures. This can cause difficulties in the case where the composition of the mixture is deemed confidential by a supplier.

Substances in Articles

An article is “an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition”.

Substances in articles only need to be registered if they are intended to be released under normal or reasonably foreseeable conditions of use. A release of substances from articles is “intended” if it fulfils an accessory function which is deliberately  planned and would not be achieved if the substance were not released. In the case of scented articles, for example, the fragrance substances need to be released in order for the article to be smelled. 

An example of this is a scented eraser. In this case, the substances contained in the fragrance would require registration under KKDIK if the 1 tonne per year threshold is exceeded.

The requirements for registering the substances in the articles under KKDIK is the same as EU-REACH - the below 2 conditions trigger the registration requirement:

1. The substance is intended to be released under normal or reasonably foreseeable conditions of use

2. The total amount of the substance present in all articles with intended release (i.e. including the amounts that are not intended to be released) produced or imported by one actor exceeds 1 tonne per year.

Monomers

There is a specific definition of a polymer and substances that meet this definition are exempt from registration. However it is necessary to register the monomer substance, or any other substance that is chemically bound to the polymer, if this is manufactured or imported at or above 1 tonne per year. This too can create challenges for companies importing polymers. 

Intermediates

Intermediates are defined in KKDIK as a “substance that is manufactured for and consumed in or used for chemical processing in order to be transformed into another substance”.

Substances that are only used on-site or transported isolated intermediates must also be registered. 

So, are you prepared for KKDIK? Do you know what has to be registered?