The directorate of the Revolving Fund of the Ministry of Environment and Urbanization has published the 2022 KKDİK fee on its website.
Compared to 2021, the fees have increased by 20%. In 2021, the joint submission fee was lesser than individual submission. The registration fee currently varies from 60 TL/€4 (for SME companies that jointly register 1-10 tonnage) to 18,000 TL/€ 1167 (for large size companies that individually register 1000+ tonnage substance) depending on tonnage band, the size of the company, and whether it is a joint or individual submission. This indicates the importance of joint registration for companies.
If you haven't pre-registered your substances yet, kindly do, so you can be part of SIEF and also to participate in joint registration.
On the 27th of September 2021, the new Turkish Food Codex Maximum of Pesticides Residual Limits Regulation was published on the official gazette, after a public consultation on the draft in 2020.
Like the Turkish Food Codex Maximum of Pesticides Residual Limits Regulation 2016, this regulation aims to protect consumers by regulating maximum pesticides residues in plants and animal source foods.
In summary of the regulation for imported goods, firstly, product code can be found in Annex 1. By using that product code, MRL (Maximum Residue Level) or LOD(Limit of Determination) should be found in Annex 3 for specific pesticides and you should comply with those. If pesticides can’t be found in Annex 3 then 0,01* mg/kg calculation applies.
Forbidden pesticides are listed in Annex 4. If pesticides listed in Annex 5 are found in imported products, then no MRL is required.
That regulation entered into force on the publication date, 27th of September, 2021, and the previous regulation is revoked by the new one. The provisions of this regulation are executed by the Minister of Agriculture and Forestry.
As published on the website of the official gazette, the Turkey cosmetic regulations’ annexes were amended in September. The parts that were amended include:
Annex 2 (List of forbidden substances)Annex 3 (List of substances that cosmetic products shouldn't contain above determined amount)
Annex 4 (List of colorants allowed in cosmetic products)
Annex 5 (List of allowed preservatives in cosmetic products
Annex 6 (List of UV filters allowed in cosmetic products)
The amendments state that:
Hair and eyelash dye products that contain Benzene-1,2,4-triol, 6-amino-m-cresol, and 2-((4-amino-2-nitrophenyl)amino)benzoic acid can’t be put into the market anymore (applicable from 3rd of September 2021). According to hazard classification and labeling of ECHA, those substances cause serious eye damage, skin irritation and may cause respiratory irritation. Additionally, products with these substances can stay in the market until the 3rd of June, 2022.
Products that contain 2-hydroxyethyl methacrylate which causes serious eye damage, and 7,7,9-trimethyl-4,13-dioxo-3,14-dioxa-5,12-diazahexadecane-1,16-diyl bismethacrylate which is harmful to aquatic life can’t be sold in the market anymore (applied from 3rd of September 2021). These substances are mainly used in nail products.
The Ministry of Health, Turkey published on their webiste the draft regulation on the amendment of Turkish Biocidal Product Regulation.
Current Biocidal regulation came into force on 31.12.2009 in Turkey. The regulation aims to assess the effects of biocidal products on humans, animals, and the environment while regulating the classification, labeling, packaging requirements, exports, licensing for biocidal products, and conditions for putting products into the market.
To prevent confusion and to make regulation more practical, this draft is prepared to amend articles regarding application for license and registration and definition of the authorized laboratory. With this amendment, this regulation will be in line with European Union Biocidal Regulation. According to this amendment, pre-application is no longer needed, and the definition of the authorized laboratory has been changed.
The Ministry of Environment and Urbanization in Turkey published an announcement about new functions added to the chemical registration system on February 15, 2021.
With the new change, the voting function will be integrated into the KKS so that potential registrants can vote for the candidate through the system. Unless there is more than one candidate or ministry requires it, appointing Lead Registrant (LR) by voting is not mandatory. Candidates should communicate with other potential registrants for LR.
After appointment, lead registrants can start notifying the Ministry about their positions from March 1st, 2021.
The fee calculator function has been added to the system. The fee is calculated depending on the size of the firm, tonnage range, and joint/separate submission.
Currently, on the system, all firms are regarded as big size firms, therefore, to benefit from a reduced fee, companies should change the size of the company and upload SME certificates that can be obtained from KOSGEB (Small and Medium Industry Development Organization website. After listing firms as small or medium-sized, it can benefit from a reduced registration fee. For foreign companies, it will require documents that show the numbers of employees and annual turnover. The fee can be paid through the online system and the Ministry is automatically notified.
GPC can undertake LR role to facilitate the registration process and communicate with other registrants. If you haven’t pre-registered your substance, please contact us and we will facilitate your participation in SIEF (including appointing LR and reduced registration cost, etc.). As your seamless extension in global regulatory compliance, GPC will act for your best interests.
The registration phase for Turkey REACH has kick-started by 1st of January 2021 as the deadline for pre-registration was passed. During the pre-registration phase, GPC has pre-registered around 3200 substances to secure business of our clients for the upcoming years in Turkey.
According to the latest updates from the ministry, the pre-registration will be possible until the end of the registration phase, 2023-12-31 but it is crucial to submit pre-registrations as soon as possible to benefit from joint registration and actively participate in SIEFs.
If you haven’t pre-registered your substances, you can send the list of your substances to us and as your seamless global regulatory extension, GPC will pre-register your substances as well as represent your company in the SIEFs. Please keep in mind that it is important to contact us as soon as possible to be able to benefit from the advantages of joint registration.
The amended SEA Regulation, the “Bylaw on Classification, Labeling and Packaging of Substances and Mixtures” (the CLP regulation) in Turkey, was published on 10 December 2020 in the Official Gazette No.31330. This amendment harmonized the EU CLP 13th Adaptation to Technical Progress (ATP) but excluding 12th ATP. Important updates are summarized here:
Nearly 110 substances were added to the classification list in Article 6
New hazards classification was added to the 108 substances
Notification applies to not only hazardous substances but all substances subject to KKDIK registration
Annexes 7-11 were removed to avoid redundancy from implementing KKDIK
This new amendment has two-years-transition periods, which reclassification and relabeling applies for substances and mixtures being placed on the market after 1 January 2023
KKDIK registered substances are exempted from classification and labeling notification
Mandated Poison Center Notification by 1 January 2025
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