Turkish REACH (KKDÄ°K)

KKDÄ°K entered into force in June 2017 and has been progressively enforced since, with registration deadlines tiered by tonnage band in a phased schedule that mirrors the EU REACH approach. Any substance manufactured in or imported into Turkey above one tonne per year must be pre-registered and, once deadlines apply to the relevant tonnage band, fully registered with the Ministry of Environment, Urbanisation and Climate Change. The registration dossier must include substance identity, physicochemical properties, hazard classification, exposure scenarios, and risk characterisation — requirements substantively identical to EU REACH but submitted to a separate Turkish database.

For non-Turkish manufacturers, the Only Representative mechanism allows a legal entity established in Turkey to fulfil KKDÄ°K obligations on behalf of the foreign producer. This OR takes on the manufacturer's registration duties, allowing downstream importers in Turkey to be treated as downstream users rather than importers for the purpose of tonnage thresholds. Choosing a qualified OR with established relationships with the Turkish regulatory authority is critical, as registration quality and response times vary widely.

A key compliance area that catches companies off guard is Turkey's independent SVHC Candidate List and its Article 7-equivalent obligation to notify authorities when articles contain more than 0.1% of a listed substance. The Turkish list is updated separately from the EU list, meaning a substance not yet on the EU Candidate List may already trigger notification duties in Turkey, or vice versa. Sustalium maintains current screening against both lists and alerts you to new additions so your article notification compliance stays current without manual monitoring.