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This article applies to selling in: Turkey

Information on the sale of Chemicals - REACH and CLP

KKDİK

KKDİK (Kimyasalların Kaydı, Değerlendirmesi, İzni ve Kısıtlanması)

The Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals (REACH, or KKDİK in Turkish), adopted based on the EC Regulation No 1907/2006, is the Turkish regulation on chemicals and their safe use. As a regulation aiming to reduce the harmful effects of certain chemical materials on human health and providing the highest protection for environment, it deals with administrative and technical principles and procedures for registration, evaluation, authorization, and restriction of chemical substances. Under the KKDİK regulation which specifies rules for production, supplying to the market and use of certain materials, manufacturers and importers are generally required to keep record of certain information on the properties of chemical substances in their products, and are generally subject to registration, authorization, restrictions, or information provision requirements. In addition, distributors and users directly or indirectly utilizing any material falling within the scope of KKDİK regulation for the purposes of their commercial activities are also generally subject to KKDİK restrictions and information provision requirements.

It is your responsibility to comply with KKDİK. This material is for informational purposes only. It is not intended as legal advice. We encourage you to consult your legal counsel if you have questions about the laws and regulations concerning your product.

General information

KKDİK applies to all chemical substances and mixtures manufactured or imported into Turkey as well as certain articles which contain prescribed dangerous or hazardous substances or mixtures.

Authorization: Particularly hazardous substances cannot be used in Turkey unless they have been authorized for that particular use. These substances will be added to KKDIK Annex XIV Authorization List after 31.12.2023. Until that date please refer to REACH’s Annex XIV Authorization List, which is available on European Chemicals Agency (ECHA) website (see Additional Information below).

Restriction: Use of certain hazardous chemicals is restricted, including limits or banning the manufacture, placing on the market, or use in Turkey. A complete list of the Annex XVII restrictions is available here or on Ministry of Environment and Urban Planning’s website (see Additional Information below).

Registration: Manufacturers and importers are responsible for collecting information on the properties and uses of the hazardous substances they manufacture or import above a certain threshold. Registration of substances must be evaluated by a certified chemical expert in accordance with the conditions defined in Annex XVIII which is available here or on Ministry of Environment and Urban Planning’s website (see Additional Information below). Pre-registration must be completed until 31.12.2020 with Annex VI on Ministry of Environment and Urban Planning’s website (see Additional Information below).

Provision of Information: Manufacturers, importers, and distributors are all responsible for communicating information about hazardous products up and down the supply chain in certain situations, which may include the provision of a Safety Data Sheet (Güvenlik Bilgi Formu (GBF) in Turkish). GBF must be prepared by a certified chemical expert in accordance with the conditions defined in Annex XVIII on Ministry of Environment and Urban Planning’s website (see Additional Information below).

It is your responsibility to provide accurate and complete product information about KKDİK-regulated products. If your products are regulated under KKDİK, verify that your products are eligible for sale in Turkey and please provide us with the most updated SDS prepared in Turkish in compliance with provisions regulating the GBF.

EU Requirements

Regulation (EC) No 1907/2006 (the “EU REACH Regulation”) applies to the sale of chemicals and their safe use in the EU. It deals with the registration, evaluation, authorisation and restriction of chemical substances. Under the EU REACH regulation, manufacturers and importers are generally required to collect information on the properties of chemical substances present in their products, which could be subject to registration, authorisation, restrictions or information provision requirements. In addition, distributors can also be subject to REACH restrictions and information provision requirements.

In addition to the EU REACH Regulation, products sold in the EU that contain relevant chemicals may also be subject to the Regulation for Classification, Labelling and Packaging of Substances and Mixtures (“EU CLP Regulation”). The CLP Regulation incorporates the classification criteria and labelling rules for hazardous chemical substances and mixtures agreed at United Nations level, the so-called Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The GHS pictograms can be found here.

There are certain other mandatory labelling requirements that you must ensure you comply with, including for example, labelling the hazardous substances with the supplier’s name, address and telephone number.

It is your responsibility to comply with the EU REACH Regulation and the EU CLP Regulation. You must also comply with other national requirements in relevant countries.

KKDİK: Additional Information

CLP and Safety Data Sheet

In addition to REACH, the Regulation on Classification, Labelling and Packaging of Substances and Mixtures (CLP Regulation; Maddelerin ve Karışımların Sınıflandırılması, Etiketlenmesi ve Ambalajlanması Hakkında Yönetmelik, in Turkish) and the Regulation on Safety Data Sheets Regarding Hazardous Substances and Mixtures (SDS Regulation; Zararlı Maddeler ve Karışımlara İlişkin Güvenlik Bilgi Formları Hakkında Yönetmelik, in Turkish) might apply to your products.

Adopted based on the EC Regulation No. 1272/2008, the CLP Regulation incorporates the classification criteria and labelling rules agreed at the United Nations level, the so-called Globally Harmonized System of Classification and Labelling of Chemicals (GHS). GHS is based on the principle that the same hazards should be described and labelled in the same way all around the world.

Note: It is your responsibility to comply with the CLP and the SDS Regulations. This material is for informational purposes only. It is not intended as legal advice. We encourage you to consult your legal counsel if you have questions about the laws and regulations concerning your product.

Application

The CLP and SDS Regulations apply to all substances and mixtures imported, manufactured, or placed on the market within Turkey unless otherwise exempted. Examples of products regulated under CLP are paints, detergents, glues, spray paints and pesticides.

The following materials do not fall within the scope of the CLP and the Safety Data Sheet Regulations:

  • Radioactive materials and mixtures including radioactive materials
  • Food and materials in direct contact with food
  • Cosmetics
  • Active implantable medical devices
  • Medical and non-medical devices used for veterinary purposes
  • Medicinal products for human use ((i) products having therapeutical and preventive impact on diseases and (ii) products used for fixing, healing or changing the physical functions/dysfunctions with pharmacologic, immunologic or metabolic effects or medical diagnostics used on humans)
  • Materials and mixtures subject to customs control while transiting for re-exporting purposes unless they are processed or subject to any other treatment
  • Non-isolated intermediary materials
  • Materials and mixtures produced or imported for scientific research and development under controlled conditions in accordance with workplace and environment legislation
  • Material mixtures deemed as waste under General Principles for Waste Management
  • Medicinal products

In order to determine if your product is regulated under CLP and provide an SDS in compliance with the SDS Regulation, we recommend you take the following steps:

  • Contact the manufacturer and ask if the product is regulated under the CLP and the SDS Regulations.
  • Check the Safety Data Sheet (SDS) (Güvenlik Bilgi Formu (GBF) in Turkish) to determine if there are CLP classifications on it. SDS must be prepared in Turkish according to Article 5 of the SDS Regulation and in the format specified in Annex-I of the SDS Regulation.
  • It is mandatory to provide explanation within the SDS prepared according to Article 5 of the SDS Regulation and in the format specified in Section 2 of Annex-1 of the SDS Regulation must address the following titles:
    • Identity of material/mixture and company/distributor
    • Description for harmfulness
    • Information on composition/content
    • First aid precautions
    • Precautions for fire fighting
    • Precautions for spread as a result of accident
    • Handling and storage
    • Exposure control / personal protection
    • Physical and chemical features
    • Stability and reaction
    • Toxicological information
    • Ecological information
    • Information on elimination
    • Information on transportation
    • Information on legislation
    • Other information
  • Explanation boxes for titles and subtitles should not be left empty even in case that information under one or more of the titles provided above are not available. If this is the case, it would be prudent to fill the empty boxes with relevant wordings such as “irrelevant”, “not applicable”, “no specific provision” etc.
  • If you do not have an SDS for the product, the manufacturer or the supplier responsible for supplying the product to the market should provide the document once you request. The manufacturer or your supplier is responsible for supplying the safety data sheet to the purchaser free of charge in a written format in hard copy or soft copy. If you think that a SDS is not compatible with the SDS Regulation and/or incomplete, you should ask your supplier or the manufacturer to complete the SDS in accordance with the legislation.
  • The SDS should be updated in following cases:
    • Receiving new information on harms or which may affect the risk management measures
    • Adoption of restrictions or prohibitions

Prohibited Products

If you participate in the Fulfillment by Amazon Service (FBA), you must not ship prohibited products into our fulfillment centers. Amazon may at your cost and without compensation to you dispose of units regulated under CLP and prohibited for sale on Amazon (please note that products classified, labeled and packed in accordance with outdated legislation (such as the Dangerous Preparations Directive) will not be accepted at Amazon fulfillment centres).

Products which bear any of the following CLP hazard (H) or precautionary (P) statements are prohibited from entering an Amazon FC:

EUH001 Explosive when dry
EUH006 Explosive with or without contact with air
EUH014 Reacts violently with water
EUH018 In use may form flammable/explosive vapour-air mixture
EUH019 May form explosive peroxides
EUH029 Contact with water liberates toxic gas
EUH031 Contact with acids liberates toxic gas
EUH032 Contact with acids liberates very toxic gas
EUH044 Risk of explosion if heated under confinement
EUH059 Hazardous to the ozone layer
EUH071 Corrosive to the respiratory tract
H200 Unstable explosive
H201 Explosive; mass explosion hazard
H202 Explosive; severe projection hazard
H203 Explosive; fire, blast or projection hazard
H240 Heating may cause an explosion
H241 Heating may cause a fire or explosion
H250 Catches fire spontaneously if exposed to air
H251 Self-heating; may catch fire
H252 Self-heating in large quantities; may catch fire
H260 In contact with water releases flammable gases which may ignite spontaneously
H261 In contact with water releases flammable gas
H300 Fatal if swallowed
H301 Toxic if swallowed
H310 Fatal in contact with skin
H311 Toxic in contact with skin
H330 Fatal if inhaled
H331 Toxic if inhaled
H340 May cause genetic defects
H341 Suspected of causing genetic defects
H350 May cause cancer
H351 Suspected of causing cancer
H360 May damage fertility or the unborn child
H361 Suspected of damaging fertility or the unborn child
H362 May cause harm to breastfed children
H370 Causes damage to organs
H371 May cause damage to organs
H372 Causes damage to organs through prolonged or repeated exposure
P222 Do not allow contact with air
P223 Keep away from any possible contact with water, because of violent reaction and possible flash fire
P230 Keep wetted with (insert manufacturer specification)
P231 Handle under inert gas
P406 Store in a corrosive resistant (insert manufacturer specification) container with a resistant inner liner
P407 Maintain air gap between stacks/pallets

Special Packaging Rules

It is your responsibility to comply with the special packaging rules for tactile warnings and child-resistant fastenings for all applicable products. An overview of the different hazards that trigger child-resistant fastenings or tactile warnings is provided by ECHA: https://echa.europa.eu/regulations/clp/labelling/specific-labelling-and-packaging-situations.

Professional use only products

Amazon fulfillment centers do not accept professional use only products. Please check with the manufacturer/GBF before shipping your products to Amazon. In the event of professional use only products being received at an Amazon fulfillment center, Amazon can at your cost and without compensation dispose of the units.

Product Listings

It is your responsibility to provide accurate and complete product information, including warning messages in the format we require. In order to add applicable warnings to your product listings, you should do the following:

  • Determine if the CLP Regulation based on (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures, or simply CLP, applies to your product. This can be verified by contacting the manufacturer or checking the product labelling.
  • If your products are regulated under CLP, verify that your products are eligible for sale on Amazon and, if you want to list them, please provide us with the most updated SDS when setting up a new item.

Special Packaging Rules

Professional use only products

Amazon fulfillment centers do not accept professional use only products. Please check with the manufacturer/GBF before shipping your products to Amazon. In the event of professional use only products being received at an Amazon fulfillment center, Amazon can at your cost and without compensation dispose of the units.

CLP: Additional Information

You can visit the UK REACH Helpdesk and review UK Government guidance for more information on REACH and CLP, including the following websites

We also encourage you to visit the Business Companion website, which contains guidance on UK product compliance rules:

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