TURKISH KKDIK OFFICIAL FEES ANNOUNCED AS A DRAFT
Some certain activities are subject to official fees under the scope of KKDİK. These can be listed as:
• Update of Registration
• A request for the information not be made available on the Internet (per Article 11(1)(a)- (11.)
• PPORD Notifications
• Applications for an authorisation
• Review of an authorisation
The Legal Text of KKDİK Express the provisions related to fees on Article 56 and these fees are to be identified every year by the Competent Authority and are to be published on the dedicated web site of Ministry of Environment and Urbanization (MoEU).
As the authorization related provisions of KKDİK will be in force as of 31.12.2023, the fees related to Authorization are not listed on the draft published. MoEU declared that such fees will be determined in future.
As the deadline for the pre-registration is approaching and registration period is due to start on the date 1st of January 2021, pre-registrants were curious about the official fees to set up their budget for possible KKDİK registrations in 2021 and further. There were some indicative drafts published earlier in 2016-2017 giving a rough idea on the expected official fees.
As of 28th of September 2020, MoEU had announced the publication of draft of the fee Schedule for KKDİK Provisions, on the web page of National Helpdesk. With a general perspective the official fees announced on the draft are found reasonable. The reason lying behind this perspective is; when compared with the REACH and REACH like regulations including the UK REACH the official fees are comparably low. With a basic comparison under the economical conditions on the date this news is texted the ratio of Registration fees KKDİK vs EU REACH is between 1/15 to 1/20 of the EU REACH relevant registration fees.
*Eur/ TL Exchange rate taken as 1 €= 9,10 TL (29th September 2020)
As CRAD when our clients who were in the need of a budget forecasting, predicted the ratio KKDİK vs EU REACH official fees between 1/8 to 1/11 of the EU REACH ECHA fees. This was in deed in line with the declared draft fees as on the dates that we as CRAD had expressed our expectation the Euro/TL exchange rate was 6,54. Based on the 6,54 exchange rate the above ration comparison was 1/11 to 1/13. As the exchange rate had increased to 9,10 TL the comparison ratio had changed significantly to the benefit of registrants from a Euro (as well USD) perspective.
Even though the draft provides a basis for indicative KKDİK budget forecast for registrants, there are still points that are subject to changes. Some of these are to be considered as;
- It should be considered that this list is a draft and still can be slightly modified till official publication.
- The Exchange rates €/TL and $/TL are highly fluctuating nowadays; this fluctuation can change the Euro converted fees listed above either side.
- Lead Registrants are expected to register earlier, but some or most of co-registrants can wait for 2023 for submission and the exchange rate and annual changes to the published fees in Turkish Lira can as well, may cause a change in either side.
- Each year the official fees are expected to be updated by the MoEU. This is mostly expected to be in alignment with the officially declared inflation rate. But need to note that the annual fee updates can be more than the inflation rate too.
- And on the top of all listed above the LoA fees are still a mystery before the Turkish KKDİK SIEF’s are formed and a data share policy with EU SIEF’s or Data owners are mutually agreed; as this is to be expected to be the significant part of KKDİK related costs of the registrants.
Indeed, Turkish Competent Authority gave a strong signal that regulatory compliance costs (at least the Competent Authority related part) should be proportionate with the market size from an economic perspective. We wish the Data Owners and EU SIEF’s & Consortia’s follow a similar policy to enable their shareholders for a seamless and cost effective KKDİK registration.
We also need to note that; as MoEU is a governmental institute, an invoice (like ECHA) for the official fees will not be raised like ECHA did for the REACH fees. Thus, the fees are transparent to all stakeholders and the registrants are obliged to pay the fees to the designated bank account declared by the MoEU.
The Legal Entities registered out of Turkey who had appointed an OR for KKDİK compliance, should transfer the official fees to their OR when they instruct their OR to submit the registration dossier without the expectation of receipt of a ‘’Official Fee invoice’’ which they get used to from REACH Registrations. . The bank voucher of the fee will be a part of documents to be submitted as a registration will not be accepted unless the relevant fee is paid.
The full list of KKDİK fees including the other activities requiring an official fee, as well the link to the official web site of help desk can be accessed via the link below:
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