Turkish chemical regulations

An Expert's View about Major Industries in Turkey

Posted on: 23 Mar 2010

F.A.Q. on turkish chemical regulations and SDS regulation in Turkey

www.crad.com.tr DGSA & Regulatory Compliance Services Turkish New Chemical Regulations During the years 2008 and 2009, there has been some changes to the Turkish chemical regulations. The new regulations affect all sectors of chemical industry in addition to cosmetics and some other industrial sectors. Q&A 1- In brief, what has changed regarding the chemical regulations in Turkey? As Ministry of Environment and Forest (MoEF) aims to align local regulations to EU and UN directives especially in chemical substances area, a fast adoption process has been projected. Within this project MoEF prepared and issued directives regarding the chemicals produced and imported to Turkey. These Regulations can be summarised as: ?SDS Directive of 27092 ?Chemical Control and Inventory directive ?Classification Labelling and Packaging of the dangerous chemicals and preparations. These directives were issued in Dec. 2008 and came into force on 26 December 2009. Additionally, there are progresses about some directives which are already in the pipeline as: ?SEVESO II ?CLP/ GHS Harmonisation ?REACH implementation ?Cosmetics directive ?Detergents directive 2- Which Turkish governmental departments are responsible for these regulations? The following regulations are held mainly by MoEF in coordination with other ministries such as Health and Occupation and Social Security. ?SDS Directive of 27092 ?Chemical Control and Inventory directive ?Classification Labelling and Packaging of the dangerous chemicals and preparations. ?SEVESO II ?CLP/ GHS Harmonisation ?REACH implementation The following directives are handled by Ministry of Health with the coordination of some other ministries and institutions. ?Cosmetics directive ?Detergents directive 3- Which sectors are affected? Main affected industrial sectors are: ?Chemicals, ?Cosmetics ?Detergent and Soap All other industries that have chemical process or ingredients are also affected at different levels. 4- What are the coming milestones and deadlines? 26 December 2009: The following two directives entered into force already on 26. Dec. 2009 ?SDS Directive of 27092 ?Classification Labelling and Packaging of the dangerous chemicals and preparations 30 June 2010: The deadline of the following directive is 30. Jun. 2010. By this deadline, all chemical substances produced or exported to Turkey should have been notified. ?Chemical Control and Inventory directive The plans for implementing the following directives were also declared by the MoEF as follows: ?SEVESO II (2010) ?CLP/ GHS Harmonisation (2010) ?REACH implementation (2013) ?Cosmetics directive (2010) ?Detergents directive (2010) 5-As an exporter to Turkey, what do I need to do right now? and which deadlines are important for me? As an exporter to Turkey, you should be in compliance with the following directives and their deadlines respectively: ?SDS Directive of 27092 To be in compliance with this directive you should supply a Turkish SDS in compliance with the directive. This SDS should be authorised by a licensed expert. ?Classification Labelling and Packaging of the dangerous chemicals and preparations: Turkish legislation is aligned with the 29th ATP of 67/548 EEC. To be in compliance with the EEC 67/548 you need to be in compliance with the Turkish directive. Turkish labels are needed. Note that both directives mentioned above came already into force on 26 Dec. 2009. ?Chemical Control and Inventory directive All chemicals produced or imported to Turkey in quantities of 1 mt/a or more should be notified to the system by a Turkish legal entity. 6- Is it allowed for a non-Turkish (LE) to carry out its compliance duties? No, Only Turkish LE can carry out the notification process. In case of imported substances, the importers or downstream users may perform the process of notification. However, to avoid sharing sensitive information about their products with importers and downstream users, the non-Turkish manufacturers may appoint a trustee or a consultant who handles the responsibilities of an importer. 8- Are there any sanctions for incompliance? Yes, there are several levels of sanctions for incompliance. Sanctions are referred to Environment Law. The most indicative one is 6000 TL/substance in case of a missing notification.
Posted: 23 March 2010

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