Related
Turkish REACH-like Chemical Regulation
The Turkish Regulation - "Inventory and Control of Chemicals"(CICR) was published on 26 December 2008 and entered into force on 1 January 2009. The Regulation imposes the obligation to notify information to the inventory of the Ministry of Environment and Forestry on all existing and new substances, either on their own or in preparation(s), imported or manufactured in Turkey in quantities above 1 tonne per year.
The regulation first was amended on 10 November 2009 to extend the submission deadline to 2010 and to add polymers to the list of exemptions. It was amended again on May 23rd, 2010 to extend the submission deadline to March 31st, 2011.
Comparison with REACH regulation
Coverage of all substances at 1 tonne is similar to REACH, but the focus is on the submission of data in the nominator's possession. Industry is responsible for providing and filling in the data, similar to REACH, but the authority keeps control. There is no data sharing, but group submission is allowed. The entire process is purely substance-driven.
Who shall be the notifier?
- Manufacturer of substance in Turkey;
- Importer of substance in Turkey;
Only Turkish legal entity can carry out the notification process. In order to comply with that, exporters might appoint a representative chemical consulting company as a trustee who acts in an importer role and handles the typical responsibilities of an importer.
What information should be submitted during notification?
Substances manufactured in, or imported into, Turkey, on their own or in preparations, in quantities greater than 1 tonne are required to have data reporting. The data requirements differ depending on the tonnage.- 1-1000 tons per year
Only basic information needs to be provided. More specifically, the notifier must provide the following information to the Ministry of Environment and Forestry:
a) Name, EC number, CAS number of the substance; Purity and impurities, molecular and structural formulas, physical state, type of substance, synonyms
b) Quantity of the substance manufactured or imported
c) Classification of the substance including hazard classification, hazard symbol, risk phrases and safety phrases, in accordance with Annex-II of the Regulation on Classification, Packaging and Labeling of Dangerous Substances and Preparations;
d) Information on foreseeable uses of the substance;
e) MSDS of the substance
f) Custom tariff number of the substance
- >1000 tons per year
a) Name, EC number, CAS number of the substance; Purity and impurities, molecular and structural formulas, physical state, type of substance, synonyms
b) Quantity of the substance manufactured or imported
c) Classification of the substance including hazard classification, hazard symbol, risk
phrases and safety phrases, in accordance with Annex-II of the Regulation on
Classification, Packaging and Labeling of Dangerous Substances and Preparations;
d) Information on foreseeable uses of the substance;
e) Data on the physico-chemical properties of the substance;
f) Data on movement and behavior of the substance among environmental media;
g) Data on ecotoxicity of the substance;
h) Data on acute and sub-acute toxicity of the substance;
i ) Data on effect of substance such as carcinogenic, mutagenic and /or toxic for
reproduction;
j ) Other related information which may be used in risk assessment of the substance
k) MSDS of the substance
l) Custom tariff number of the substance Regulation on Inventory and Control of Chemicals
How to determine tonnage band? When is notification deadline?
Manufacturers or importers who have manufactured or imported substances on their own or in a preparation in quantities of more than 1 ton within the preceding three years from 01/01/2010, shall submit the three years average quantities and corresponding information to the ministry at the latest until the date 31/03/2011.
Manufacturers or importers who have manufactured or imported substances on their own or in a preparation for the first time, in quantities of more than 1 ton per year from the date 01/01/2010, shall submit the information to the Ministry within the consequent three months after one year from the date which the substance was produced or imported for the first time.
How do I know if my substance is exempted or not?
Substances which fall into any of the categories below are totally exempted from the requirements of CICR.- The substances in transit which are subject to customs supervision, provided that they do not undergo any treatment or processing.
- The substances manufactured or imported for use in military purposes.
- Substances that are < 1 ton/year
Annex I of CICR give exemptions to substances that meet certain criteria.
- Substances that naturally occur in nature, which are not chemically modified such as: Minerals, ores, ore concentrates, cement clinker, natural gas, liquefied petroleum gas, natural gas condensate, processed gases and components thereof, crude oil, coal, coking coal.
- Basic natural chemical substances about which sufficient information is available regarding their intrinsic properties including their risks and hazards, such as: Hydrogen, oxygen, noble gases (argon, helium, neon, xenon) and nitrogen.
- Chemicals listed in Annex-I Part 3(pdf.)
- Polymers
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.
Our Services
We work with our partner in Turkey and provide comprehensive chemical compliance services in Turkey. Those services include:
- Assess your obligations;
- Prepare the data required for notification (1-1000t and 1000t+);
- Submit notifications in Turkish in the format required;
- Turkish MSDS;
Contact
- CIRS China
11F Building 1, Dongguan Hi-Tech Park, 288 Qiuyi Road, Binjiang District, Hangzhou 310052, China
Tel: +86-571 8720 6555 | Fax: +86-571 8720 6533
Email: service@cirs-reach.com