F.A.Q. About Turkish Chemical Regulations

An Expert's View about Metals, Metalworking, Glass and Minerals in Turkey

Posted on: 23 Mar 2010

On this document prepared by CRAD you may find a brief info on Turkish Chemical related regulations.

FAQ?s about the Turkish Chemical Legislations 1- In brief, what has changed regarding the chemical regulations in Turkey? Briefly previously there were no Turkish Chemicals Inventory. As MoEF aims to align local regulations to EU and UN directives especially about the chemicals a fast adaption process has been projected. With in this project MoEF prepares and issues directives regarding the produced and imported chemicals. These Regulations can be summarised as : ? SDS Directive of 27092 ? Chemical Control and Inventory directive ? Classification Labelling and Packing of the Dangreous cehmicals and preparations . Those directives are issued on December 2008 and comes in to force on 26 December 2009. And also there are progresses about the 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? Below mentioned regulations are mainly held by MoEF and other Ministries such as Health and Occupation and Social Security are in coordination. ? SDS Directive of 27092 ? Chemical Control and Inventory directive ? Classification Labelling and Packing of the Dangreous cehmicals and preparations . ? SEVESO II ? CLP/ GHS Harmonisation ? REACH implementation And Below listed directives are handled by Mo Health,with the coordination of the other ministries and institutes. 3- Which sectors are effected (chemical industry, cosmetics, food-related, ...) Most effected industries are : ? Chemicals, ? Cosmetics ? Detergent and Soap All industries that has chemical process or ingredients are also effected in different levels CRAD Çevre Risk Analiz Denetim ve E?itim Hizm.Ltd.?ti. Atakent Mh.Türkler Cd.Göktürk Sok. No:8/A Ümraniye /?stanbul Tel: 0216 335 46 00- 0216 4430763 Fax: 0216 3354606 www.reach.com.tr e-mail: info@reach.com.tr 4- What are the coming milestones and deadlines? ? SDS Directive of 27092 ? Classification Labelling and Packing of the Dangreous cehmicals and preparations Above mentioned directives will come in to force with a dead line of 26 December 2009. ? Chemical Control and Inventory directive ( Dead line ammended as 30 June 2010) And the plans for implementing the below mentioned directives are also declared by the MoEF ? 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 below mentioned directives by their deadlines respectively: ? SDS Directive of 27092 Briefly to be in compliance with this directive you should supply a Turkish SDS in compliance with the directive which is authorised by a licenced expert . ? Classification Labelling and Packing of the Dangreous cehmicals and preparations: Turkish legislation is aligned with the 29th ATP of 67/548 EEC. To be in compliance with the EEC 67/548 also maintains to be in compliance with the Turkish directive.Turkish labels are needed. Above mentioned directives will come in to force with a dead line of 26 December 2009. ? Chemical Control and Inventory directive ( Dead line ammended as 30 June 2010) All chemicals that are produced in Turkey or imported to Turkey should be notified to the system by a Turkish LE with a lower limit of 1 mta. Inorder to comply with that exporters to Turkey might appoint a trustee or consultant which handles the reposibilities of an importer and prevent them to share all ingredients with the clients. 6- Is it allowed for a nonTurkish (LE) to carry out its compliance duties? No , Only Turkish LE can carry out the notification process. 7- Is there any obligation to assign a representing Turkish legal entity? That might be one of the choices, but many companies prefer to appoint a representative to chemical consulting companies as a trustee and importer role. 8- Are there any sanctions for incompliance? Yes there are several levels of sanctions for incompliance. The most indicative one is 6000TL/substance in case of a missing notification and also prevention of importing. CRAD Çevre Risk Analiz Denetim ve E?itim Hizm.Ltd.?ti. Atakent Mh.Türkler Cd.Göktürk Sok. No:8/A Ümraniye /?stanbul Tel: 0216 335 46 00- 0216 4430763 Fax: 0216 3354606 www.reach.com.tr e-mail: info@reach.com.tr 9- How much might the compliance process cost? A fixed retainer of 500 ? independant from the substances. Notification , legal follow up and responsibility duty is priced in two levels respective to the annual tonnage theresholds: Notification for substances between 1-1000 mta : Notification for Substances higher than 1000 mta: Legal follow up and responsibility for substances between 1-1000 mta : Legal follow up and responsibility for Substances higher than 1000 mta: Also additional services and request of additional information from legal authorities the consultancy support is supplied by a 100 ? hourly rate at the principal consultant level of service. CRAD Çevre Risk Analiz Denetim ve E?itim Hizm.Ltd.?ti. Atakent Mh.Türkler Cd.Göktürk Sok. No:8/A Ümraniye /?stanbul Tel: 0216 335 46 00- 0216 4430763 Fax: 0216 3354606 www.reach.com.tr e-mail: info@reach.com.tr
Posted: 23 March 2010

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F.A.Q. About Turkish Chemical Regulations   By CRAD CEVRE LTD.STI.
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