KKDIK obligations depend on tonnage; Therefore, accurate and continuous monitoring of annual production/import amounts is critical.
Tonnage tracking; It determines which substance is in which band, thus the data requirement and registration obligation. Tonnage exceeding a band may require new data and updates; The decrease in tonnage produces different results.
Especially in Exclusive Representative structures, the tonnage of many importers should be monitored centrally. ONAY Mühendislik carries out tonnage tracking systematically.
The Role of Tonnage in Determining Liability
The scope and depth of liability under KKDIK varies depending on the annual amount of the substance. While there is no registration obligation for substances below one ton per year, if the threshold is exceeded, a full registration file and a chemical safety report are required after a certain level. For this reason, tonnage tracking is not an accounting task, but a measurement that directly determines regulatory liability.
Accurate Calculation Base
Tonnage calculation is made on a calendar year basis and on a legal entity basis. For a company that both produces and imports the same item, the quantities are summed. Special rules govern how quantities produced for export and quantities re-imported are counted. Making the calculation based on the weight of the pure substance requires a proportional calculation for the substance in the mixture.
Early Detection of Threshold Approach
Log file preparation can take months, along with the necessary testing and data sharing processes. The preparations that begin when it is realized that the threshold has been exceeded are usually too late. For this reason, it is recommended that monitoring be done monthly, not at the end of the year, and that an automatic alert is generated when a certain rate of the threshold is reached.
Tonnage Band Change After Registration
Tracking continues after registration is completed. Moving the production or import amount to a higher tonnage band requires updating the file with additional data requirements for that band. Operating in the upper band without updating means non-compliance, even though it is registered.
Establishing the Tracking System
For effective tracking, purchasing, production and foreign trade records must be combined on an item-by-item basis. Consolidation should be done through the CAS number, not the commercial product name; The same substance may come under different trade names from different suppliers. This established structure facilitates tonnage tracking as well as keeping the safety data sheet inventory up to date.
A Simple Alert Threshold for Annual Tonnage Tracking
There is no need to complicate the Annual Tonnage Tracking system; A simple table that automatically generates alerts when a certain percentage of the registration threshold is reached is sufficient in most companies. The important thing is that the data is collected on the basis of CAS number. When Annual Tonnage Tracking is done by trade product name, the threshold is not noticed at all because the same substance appears under different names.
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Official full text of the regulation: KKDIK Regulation - Official Gazette.