— SERVICES —
KKDİK CONSULTANCY
ARE YOU TRADING CHEMICAL SUBSTANCES
WITH THE EU MARKET?
If you are a company that is marketing chemical substances in the European Union market, you have to comply with the 1907/2006 numbered REACH Regulation by the European Parliament, dating from 18 December 2006, that stands for "Registration, Evaluation, Authorisation and Restriction of Chemicals".
Chemical substance manufacturers who export their products to the European Union are obliged to assign a SOLE REPRESENATIVE to fulfill their liabilities in accordance with REACH and to protect confidential company information.
REACH registration of a chemical is a complicated process and in addition to serious efforts that need to be shown by manufacturers and importers, may require expert consultants. Sole Representative executes and becomes responsible in the name of the importer for all obligations related to registration process and REACH legislation. Third party representative, on the other hand, is the representative that companies based in Turkey may appoint in order to protect the confidentiality of company identity information during the registration process.
WHAT IS REACH?
REACH (Registration, Evaluation, Authorisation and Restriction of CHemicals) is a European Union regulation that collects numerous legislations related to chemicals in the EU under one roof. The regulation is referred to as KKDİK in Turkish and its primary goals are as follows:
- To protect human health and environment from damages caused by chemicals on a high level.
- To enforce chemical substance suppliers (manufacturer, importer) to ensure safe usage of chemicals.
- To improve innovation and competition within Turkish chemistry industry.
- To reduce the need for animal experiments used for assessment of hazardous properties of substances and to encourage alternative methods (Ex. QSAR and Read Across).
REACH Regulation spans production and supply of chemical substances directly as they are or indirectly inside a mixture or other goods. The registration, evaluation, authorization and restriction procedures of substances will be carried out by Ministry of Environment and Urbanization of Republic of Turkey according to REACH provisions.
SOLE REPRESENTATION
SERVICES
3RD PARTY REPRESENTATION
A natural person or a legal entity who manufactures or a substance, outside of Turkey for the purpose of being imported to the country, purely as it is, within a mixture or inside other goods, prepares a mixture or produces such goods is called a Sole Representative. An importer within the scope of REACH can assign a "Sole Representative" to fulfill its obligations based on a mutual agreement.
In case of representative assignment, the assigned representative will be responsible for fullfiling the importer obligations according to REACH. The representative is also required to have sufficient information about the substance, usage of substance; imported amounts, the customers to whom substance is to be sold and for obtaining the most recent update of Safety Data Sheet.
When a sole representative is assigned, the producer who is based outside of Turkey informs the importers who exist in the same supply chain. In accordance with the legislations of the specified regulation, such importers are accepted as subusers. In such a situation, the importers who are located in Turkey, will not have registration obligations since they will be accepted as subusers of the sole representative.
- Delegation servie to act in your name for pre-registration process in Turkey
- Pre-registration data collection and presentation for every substance (pre-MBDF)
- World wide REACH expertize for supporting technical matters related to pre-registartion phase (pre-MBDF).
- Pre-MBDF registration of chemicals for REACH
- Consultancy support for all your questions until pre-MBDF process
- Direct access to TÜV REACH Experts Help Desk
- Attendance to MBDF, including contact with MBDF members and coordination
- Application to REACH registartion
- Creation and presentation (if necessary) of REACH checmical safety reports (KGR)
- Preparation of Safety Data Sheets that comply with REACH (REACH add II)
- Unlimited support for your questions about REACH and coorperate training service
- Most up-to-date notifications about legal or sectoral changes in information about REACH
- Sending chemical data to Substance Information Exchange Forum (SIEF) through EÇBS
- Data exchange and evaluation
- Dispute with MBDF and Consortium Members
- Collecting technical files and presentation
- Contact with subusers about substances
- Amounts of produced/imported products to ÇŞB and related risk assessment
A Manufacturer, importer or a sub-user in related cases can assign a "Third Party Representative" related to topics about data and cost exchange with other producers, importers and related sub-users, subject to the condition that obliging with REACH regulations belongs to itself. Information about the producer, importer or sub-user who assigns a representative will not be disclosed to other producers, importers or sub-users by the ministry.
Our Third Party Representative Services:
- Protection of client identity and confidentiality
- MBDF or Consortium attendance and representation for all matters with the board
- Exchange management for data and work with other attendees
- Demanding deficient information from other MBDF members
- Defining and attendance to editing activities that provide deficient data
- Helping prepare mutual record delivery
- Functioning as a point of contact with manufacturers, importers and sub-users on REACH substance registration related topics
- Data acquisition and combination
- Complete REACH registration service including file preparation, tests and application preparation
- Preparation of REACH compatible Safety Data Sheets (KKİDK ATT II)