11 October 2022 LR & OR Event by MoEUCC Regarding Data Sharing and Progress of KKDIK

Content addition date : 13-10-2022

An event organised by Turkey’s Ministry of Environment and Climate Change (MoEUCC) targeting the Lead registrants & Only Representatives took place at the ministry’s premises in Ankara with the attendance of 150 stakeholders.

The Programme Started with a welcome speech and introduction by Mr. Ethem Yaman; president of the Chemical Management Unit (CMU). After this introduction Mr. Bektaş Kılıç, Chemical Engineer at the CMU, presented the actions the ministry has already taken and those intended in the future in bullet points.

The CA mentioned KİMVES, a new online platform for public data dissemination. Currently, only C&L information can be found on the system but in future KKDIK information will also be disseminated on the platform.

Further steps to be considered by the CA are listed as below;

  • Regulatory activities about cost of data sharing.
  • The process on submission of the list of importers.
  • Provisions about LR identification and submission date of LR dossiers.
  • Supervision and identification of criteria for OR’s.
  • Audits on training institutes.

CA mentioned their expectations from the stakeholders as follows:

  • Accurate and compliant data submission.
  • Effective communication within KKDIK SIEFs.
  • Timely and fast progress on registration.
  • Efficient, transparent, and fair data sharing condition with clear and non-discriminative cost definition.

Following the ministry’s presentation, the floor opened to a Q&A session. 

There were questions from the audience about the registration deadline and how early the LR’s are expected to submit the LR dossiers. Ms. Ahu Çekim from the CA stressed that the ministry does not intend to extend the general deadline but will consider how quickly after that date the LR’s might be invited to submit their dossiers. They said that 504 LR dossiers submitted so far are far below their expectations. Stakeholders including CRAD explained the reasons behind the slow progress, some of which are due to issues that can be resolved by the CA. One issue is the importer listing obligation at the first instance and the CA was asked for time-based flexibility, for examplefor this to be completed at a later time during or even after the submission of dossier. 

The officials at CA said that, in cases where there is strong conflict about the cost of data sharing, they may consider data to be re-generated at local labs and expressed that they are in 
the process of coordinating with some labs for an increase in activity and capacity. This might be considered as an option in cases where the data owners are not offering/sharing the data at a rational or fair cost. 

Some companies (who were the LR of significant number of substances under the scope of REACH) mentioned that they have a ‘’wait and see” policy for the substances that they are the LR for EU REACH but don’t have a registration intention for KKDİK due to low level of volumes in Turkey. Their intention is to wait for an alternative LR candidate but if no LR shows up they will aim  to take the initiative as the data holder. 

The CA is aiming to publish a communique/ circular note with solutions to the issues raised by stakeholders & particularly Experienced OR’s and LR’s. 

Along with the Questions raised at the meeting many questions have been submitted in writing. The ministry said it will address those in the FAQ section of the Helpdesk. 

In the last part of the event, Mr. Yanar made an improvised speech expressing the importance of timely submissions, their expectations from stakeholders and how they should be cooperative, and the importance of data collected via KKS in the context of human health and environment of Turkiye. The event ended with closing remarks from Mr. Yaman and with the aim to increase the frequency of stakeholder meetings where required. 

Yours sincerely 
CRAD Team