KKDIK registration process requires expertise in chemical regulation. Experts must follow legal regulations in the related transactions. Managing the process correctly requires both technical expertise and regulatory expertise. This way, it is possible to avoid challenges in KKDIK registration.
Considering the scarcity of experienced individuals in the sector in this regard, especially for companies without an experienced in-house team, the REACH registration process can be challenging and complex. This can lead to time and cost losses for the company.
Some potential challenges that may arise during the REACH registration process include:
- Technical issues
As known, processes related to KKDIK are conducted through the online platform Chemical Registration System (KKS) of the Turkish Ministry of Environment, Urbanization and Climate Change. During these processes, internet connection or system problems may occur.
Especially since the KKS notification for registration is a time-consuming process, any internet interruption or brief deactivation of the system requires the entered information to be checked twice. - Information overload
One of the biggest challenges that non-experts may face when entering the KKDIK registration process is undoubtedly information overload. As known, the KKDIK Regulation is a regulation harmonized for Turkey with reference to the EU REACH Regulation. Although the two regulations are similar, there are some differences in practice.
Especially since the data used for REACH is also valid for KKDIK, there is no need to repeat existing tests. Therefore, most tests do not have a waiting period during the KKDIK registration. However, related persons must obtain the “right to use data”. This process progresses in various ways during the KKDIK registration. The guide containing detailed information is the “Data Usage Guide”. - Compliance issues
There have been updates to the implementation and requirements of the KKDIK Regulation in line with sectoral needs. To avoid any compliance issues, it is necessary to closely monitor sector-related news, updates, and changes. - Inexperience in the use of KKS
As mentioned above, lack of information during the use of KKS, like in the cases of “Information overload” and “Compliance issues” will cause non-experts in the field to encounter problems during the KKDIK process.
For this process to proceed smoothly, it is necessary to be experienced and knowledgeable not only in terms of chemical regulations but also in the use of online tools for KKDIK registration processes. This prevents taking the wrong steps and extending the process unnecessarily. - Document shortage
During the registration obligation imposed by the KKDIK Regulation, there are certain requirements. We can summarize these as the information and role of the registrar, as well as information regarding the chemical and having the right to refer to the information provided.
Failure to submit these documents or not submitting them at all may result in applications being rejected and the KKDIK registration process failing. - Language barriers
When official documents are involved, the correct use of language is crucial. For foreign companies, it would be beneficial to seek support from individuals whose native language is Turkish during the KKDIK application process. - Security and confidentiality
The security and confidentiality of companies during the KKDIK registration process are also issues to be considered. Companies should prefer to work with reliable consultancy firms to ensure that these are not violated. Additionally, they have the right to request confidentiality from the relevant Ministry for certain information that needs to remain confidential. - Time management
We can divide the KKDIK registration process into two parts: “Technical section”, which includes the preparation of the registration dossier and its submission to the Ministry, and the “pre-MBDF communication process”, which involves monitoring the processes and obtaining the Access Letter.
Especially for Lead registrants, the translation of the technical part and the submission of the dossier to the KKS system are quite time-consuming tasks.
Companies may fall into the misconception of postponing their KKDIK translations and registrations to the last minute, thinking that these processes will not take much time. However, translation and registration notification are tasks that must be carried out meticulously by experts in the field. Delaying tasks until the last minute can lead to problems in completing the registration on time.
The “pre-MBDF communication process” is also quite time-consuming, as it involves the Lead registrant obtaining rights from the data owner and determining prices, as well as the Co-registrants following the designated paths regarding the set fees and completing the contract processes. Pricing processes for Access Letters, which can take up to a year, clearly indicate that KKDIK registration should not be left until the last minute for both Lead registrants and Co-registrants.
It is inevitable for applicants or registrants to encounter such challenges in KKDIK registration process that is not managed correctly. However, if the process is conducted following current legislation and correctly, the process will be completed without encountering such challenges in KKDIK registration. To take careful and correct steps during this process, it would be beneficial to seek consultancy from a reliable firm, thus minimizing the possibility of encountering the difficulties mentioned above and putting companies in an advantageous position in terms of time and cost.
You can contact us to benefit from our support during the KKDIK registration process.