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Are the substances in goods subject to KKDIK?
Substances in goods give rise to KKDIK liability under certain conditions. Furniture; An object whose shape, surface or design is more decisive than its chemical composition. A textile product, toy, electronic card or packaging falls within this definition. Whether registration or notification is required depends on whether the substance has been released and its quantity.
When are substances in articles subject to registration?
The criterion is intentional oscillation. If a substance is released due to the function of the article, for example a scented eraser or moisturizing glove, this substance may be subject to registration. If the substance released exceeds 1 ton per year, a registration obligation arises. On the other hand, if the substance remains in the goods and is not released, no record is required.
SVHC and notification obligation
Substances of very high concern (SVHC) are a separate heading. If such a substance is above a certain weight ratio in the goods and above the annual tonnage threshold, notification will be brought to the agenda. Additionally, an obligation arises to provide information to the supply chain. This information is transmitted in certain cases, even if the recipient does not request it.
Practical steps for the importer
- Divide product portfolio into product families
- Collect bill of materials and ingredient declaration for each family
- Confirm in writing with the manufacturer whether there is an intentional release
- Get SVHC screened and keep dated results
- Establish a recording or notification plan for items exceeding the threshold
Why is the supplier declaration not enough?
In practice, companies close the file by saying "the supplier said it was suitable". However, the responsibility lies with the company that places the goods on the market in Turkey. It is important which analysis the declaration is based on, on which date and for which party it is made. For this reason, we recommend that you request the statements together with the analysis reports.
Difference between mixture and item
The paint in a paint can is a mixture; When it remains as a coating after drying, it is considered an article component. This distinction changes what liability arises. For mixtures, classification, labeling and, when necessary, UFI code come into question. For goods, registration and notification criteria are applied.
Related pages
Official full text of the regulation: KKDIK Regulation - Official Gazette.
For questions, contact ONAY Mühendislik.
Which sectors are most affected?
Textile, toys, furniture, electronics, automotive sub-industry and packaging sectors come first. These products contain multiple components and a multi-layered supply chain. Therefore, gathering information is much more demanding than for a single chemical product. In practice, the most efficient way is to create a standard ingredient declaration form on a product family basis and make it mandatory for all suppliers.
What is required in the audit?
In the audit, the product list, ingredient declarations, analysis reports, if any, and release evaluation are generally requested. Documents are expected to be dated and traceable. An incomplete file may lead to processes leading to the withdrawal of the product from the market. Therefore, it is much cheaper to do the evaluation at the product development stage than to fix it later.