Reminder: Fewer than Two Weeks Remaining to Complete Chemical Registrations in Turkey
There are fewer than two weeks remaining to complete registrations under Turkey’s new “Bylaw on the Inventory and Control of Chemicals.” March 31, 2011, is the deadline for registering chemical substances imported or manufactured at or above 1 metric tonne per year. Turkey’s Ministry of Environment and Forestry (MoEF) will use the information to establish a chemical inventory and regulate “priority chemicals.” The bylaw is part of a suite chemical-related bylaws Turkey enacted in 2008 in preparation for joining the EU. The other two bylaws concern safety data sheets (SDS) and the classification, labeling, and packaging (CLP) of dangerous substances and preparations. A short summary of each bylaw is provided below.
Chemical Inventory and Control Bylaw
The registration requirements are set out in Articles 7 and 8. Article 7 imposes substantial data requirements for substances imported or manufactured above 1,000 metric tonnes per year. The information requirements for quantities below that threshold are minimal; they’re similar to the EU’s pre-registration requirements under REACh. Turkey’s bylaw also provides exemptions similar to those available under REACh. However, some of those are identified only in a guidance document currently available only in Turkish. Lastly, registration is limited to Turkish entities, meaning that some companies will need to use an Only Representative (OR) to perform the registration, should one be required.
SDS and CLP Bylaws
Turkey also enacted bylaws concerning the classification, labeling, and packaging of dangerous substances and preparations, as well as the preparation and distribution of Safety Data Sheets. The classification and labeling requirements are based on the EU’s Dangerous Substances and Preparations Directives. The SDS requirements are similar to the EU’s, but a person certified by Turkish authorities must prepare the SDS and submit it electronically to MoEF.
* * * *
Additional information about Turkey’s new bylaws is available here.