There is little time left for the registration process to begin under the Turkish REACH Regulation KKDIK
According to KKDIK Regulation,
- If the annual amount is equal or more than one ton for the substances imported into Turkey on their own or in a mixture before 31/12/2023 the registration provisions of KKDIK regulation is applied between 31/12/2020 and 31/12/2023 (Provisional Article 2).
- After 31/12/2023 substances cannot be placed on the market without registration.
- No Data No Turkish Market
As it is known the following considerations are subject to the fee as per the KKDIK regulation
- Registration
- Registry update
- Request the information not to be made available to the public
- PPORD notifications
- Authorization applications
- Reviewing the authorizations
Many days before the start of the registrations; The Draft KKDIK Fees List has been published which includes fees for registration, registration updates, requests for information not to be made available to the public and fees for PPORD notifications.
The final list will be published at the beginning of the year 2021 by MoEU in the unit price list of the revolving capital transmission.
Since the permits will enter into force on 31/12/2023, the fees for the authorization will be determined later.
Small and Medium-sized Enterprises can benefit from reduced fees under KKDIK Regulation. The reductions depend on the company size as defined by the link https://en.kosgeb.gov.tr/site/tr/genel/detay/5667/definitions-and-regulations and can be up to 80-95 % or more from the standard fee for a KKDIK registration.
For Only Representatives (ORs), the pertinent assessment of whether the fee reduction for SMEs applies shall be determined by the relevant data of the enterprise that is represented by that OR, including relevant information from linked and partner companies of that enterprise, in accordance with the Ministry Recommendation.
It is important to get this right. If you wrongly declare your company size, you will have to pay an administrative charge and the balance to the correct fee.
Remember that it is you, the registrant, that is entirely responsible for the correctness and authenticity of the information provided in the process of the dossier submission in KKS. The MoEU does not assume any responsibility for the accuracy of the advice given by third parties to determine your company size or the size of the company or you represented by an Only Representative.
As an example, a micro sized European enterprise can be categorized as small sized enterprise in Turkey. It is important to determine your enterprise size carefully.
Reduced fees are described for the applications of SMEs. There is also a significant cost advantage for companies that make co-registration.
Defined minimum fee for registration; 50 ₺ (Turkish Lira) for a micro sized enterprise including joint submission of 1-10 tons of substance.
The highest fee is determined as 15000 ₺ for a large enterprise preferring a single submission of 1000 tons of a substance.
You can download the tables for the fees from the link below.
“How to determine the company size category” is a critical issue for KKDIK. You will need support on this issue. Contact to kkdik@doruksistem.com.tr
No need to take a risk.
Just contact to kkdik@doruksistem.com.tr
KKDIK Registrants will gather on www.kkdik.net.tr soon to find their KKDIK MBDF (TR-SIEF) partners.
Please keep your notice on this site to find or follow your KKDIK MBDF co-registrants.
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