Ana sayfa/Are polymers subject to KKDIK?
Are polymers subject to KKDIK?
As under REACH, polymers themselves are generally exempt from registration under KKDIK (Turkey REACH). However, this exemption is not absolute: the monomers and other reactive substances that make up the polymer, present above certain thresholds, may be subject to registration when at 1 tonne per year or more. Companies manufacturing or importing polymers should therefore carefully assess the registration status and tonnage of the monomers used. Classification, labelling and SDS obligations for the polymer may still apply. Expert analysis of the substance and monomers is important to clarify your exemption scope. ONAY Mühendislik assesses polymer and monomer registration.
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Polymers and the monomer rule
Polymers themselves are generally exempt from registration, but that exemption does not extend to the monomers. Where a monomer is present above the defined percentage and the annual quantity passes the threshold, it must be registered. Saying “our product is a polymer” therefore does not close the file.
What to check
- Identity and share of each monomer used
- Annual quantity of monomer in the polymer placed on the market
- Other reactants present above the threshold
- Whether the material meets the regulatory definition of a polymer
Imported polymers
An importer of a polymer needs composition data from the supplier to run this calculation. Suppliers are often reluctant to disclose it, in which case a confidentiality agreement or a third-party declaration is the usual solution. Without that information the obligation cannot be assessed at all.
Documenting the conclusion
Whatever the outcome, record the reasoning with dates and supporting figures. An exemption is a documented position, not an assumption, and inspectors ask for the calculation rather than the conclusion.
Related pages
Official source: KKDIK Regulation — Turkish Official Gazette.