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KKDIK NEW AMENDMENTS TO THE “1.7 SUPPLIERS” AND “13.1 CHEMICAL SAFETY REPORT”

INFORMATION REQUIREMENTS IN REGISTRATION FILES

NEW AMENDMENTS TO THE “1.7 SUPPLIERS” AND “13.1 CHEMICAL SAFETY REPORT” SECTIONS IN THE REGISTRATION FILES

The announcement published in the Chemical Registration System on February 2, 2023 is given below.

1.7 Suppliers

As it is known, only representatives are required to add the importers in Turkey of the foreign company they represent in the “1.7 Suppliers” section of their registration files.

As a result of the evaluation of the opinions and suggestions received from sector unions, associations and various companies by the Ministry, it has been deemed appropriate to remove this information requirement from being mandatory.

In this context, although it is recommended that only representatives add the aforementioned information to their registration files, failure to do so will not constitute any deficiency in the completeness checks to be carried out by the Ministry in the registration files.

The registration file of the only representative should include all uses of importers (now sub-users) covered by the registration. The only representative must keep an up-to-date list of the ‘non-Turkish manufacturer’s’ customers (importers) within the same supply chain and the tonnage covered for each of these customers, as well as information on the supply of the most recent update of the safety data sheet, and submit this information during inspections by the Ministry.

In this regard, the information in the already published guides such as the “Registration Guide”, “CDS User Guide” and the “Frequently Asked Questions” section of the Chemicals Helpdesk will be updated as soon as possible.

Some of the issues that sole representatives and importers should pay attention to regarding the registration of chemicals are as follows. Detailed information can be found in the “Registration Guide” on the Chemicals Helpdesk:

Importers should obtain confirmation from the ‘non-Turkish manufacturer’ as to whether an only representative has been appointed. In addition, they are strongly advised to obtain written confirmation from the only representative that the imported tonnage and use is indeed covered by the registration submitted by the only representative. This will provide the importer with a point of contact where they can report their use if they are considered to be a downstream user and will also give the importer a clear indication that their imports are indeed covered by the sole agent’s registration. In addition, the importer is required, where relevant, to obtain sufficient information from the ‘non-Turkish manufacturer’ and/or sole representative to fulfill the obligation to compile the safety data sheet. The importer in Turkey should be in a position to document, if requested by the Ministry, which of its imports are covered by the registration to be made by the only representative.

The only representative’s registration file must include all uses of importers (now downstream users) covered by the registration. The only representative must keep an up-to-date list of the ‘non-Turkish manufacturer’s’ customers (importers) within the same supply chain and the tonnage covered for each of these customers, as well as information on the supply of the most recent update of the safety data sheet, and submit this information during any inspection by the Ministry.

13.1 Chemical Safety Report

It has been stated that the translation of Chemical Safety Reports, which must be submitted in the registration dossiers of chemicals over 10 tons per year, takes a long time and causes additional costs due to the expiration of the registration period at the end of this year, and in this context, the option to upload the Chemical Safety Report in English language has been introduced for companies that wish to do so.

However, registrants who prefer to upload the Chemical Safety Report in English language are required to add a Turkish translated version to the registration file, including uses in Turkey, exposure scenarios and risk management measures, within 1 (one) year from the registration deadline of December 31, 2023.

On the other hand, all fields in the system for “Comprehensive Study Summaries” and “Study Summaries” to be submitted in the registration dossier must still be filled in Turkish.

***REGISTER YOUR CHEMICALS WITHIN THE SCOPE OF THE REGULATION UNTIL 1.1.2024. THE MANUFACTURE AND/OR IMPORT OF SUBSTANCES THAT ARE NOT REGISTERED IN THE CHEMICAL REGISTRATION SYSTEM UNTIL 1.1.2024 WILL NOT BE ALLOWED.***

Source: https://kimyasallar.csb.gov.tr/kayit-dosyalarindaki-bilgi-gereklilikleri/365

 

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