Companies importing chemicals have important obligations within the scope of KKDIK. A checklist allows you to foresee deficiencies.
To be checked: inventory and tonnage of all imported substances and mixtures; whether the foreign manufacturer has appointed an Only Representative; registration status and registration numbers; current SDSs; SEA/CLP label compliance; Mixtures requiring UFI/PCN; subuser obligations.
ONAY Mühendislik provides a comprehensive compliance screening and remediation plan for importers.
Substance Inventory
The first item of the checklist is an item-by-item breakdown of all imported products. If the mixture is imported, each substance in it is evaluated separately, not the mixture itself. It is essential that the inventory is established based on the CAS number rather than the commercial product name; The same substance may come under different names from different suppliers and the tonnage total can only be calculated correctly in this way.
Verifying Registration Status
It should be clear who made the recording for each substance. If the foreign manufacturer has appointed a sole representative, the importer is a downstream user and does not have a registration obligation; However, this situation must be documented with a sole representative appointment letter. If there is no sole representative, the liability lies directly with the importer and is evaluated based on the tonnage threshold.
Checking Document Set
For each shipment, a safety data sheet in Turkish and in accordance with the SEA Regulation, a certificate of analysis and, if necessary, a letter of conformity from the relevant ministry must be available. Mixtures must also have the UFI code on the label and a PCN declaration must be made. Checking documents before shipment eliminates most of the cost of waiting at customs.
Label and Packaging Compliance
The original labels of imported products are mostly prepared according to the legislation of the country of origin. Before being placed on the market in Turkey, the label must be in Turkish, the hazard and precautionary statements must exactly match the official texts in the CLP Regulation, and the supplier information must indicate the responsible company in Turkey. Using free translation is the most common inconvenience.
Annual Review
The checklist is not a one-time exercise. Tonnage totals, supplier changes, classification updates and new substances placed on restriction lists should be reviewed at least once a year. The dated record of this review is used as evidence that the firm exercised due diligence in the audit.
How Often Should KKDIK Compliance Check List Be Repeated?
KKDIK Compliance Checklist is not a one-time study. In case of supplier changes, new product introductions and legislation updates, the relevant articles are reviewed; The entire list is re-run at least once a year. The dated record of the KKDIK Compliance Checklist study is proof that necessary care was taken in the audit.
Related pages
Contact ONAY Mühendislik for your process.
Official full text of the regulation: KKDIK Regulation - Official Gazette.
The first document that the importer will request from the supplier is the Turkish MSDS document. An MSDS in a foreign language alone is not sufficient; The document must be rearranged according to Turkish legislation.
Use the distinction in the KKDIK guide to downstream users section to determine whether you are an importer or a downstream user.
You can review our PCN file service to prepare the notification file.