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April 9, 2010

Turkey Begins Consultation on Chemicals Inventory Deadline Extension

The ACTA Group

Companies located in European Union (EU) countries have expressed relief at news that they may have won more time to comply with a significant new chemicals control law adopted by the Turkish government. This memorandum explains why.

Meeting of Interested Parties

A delegation of EU chemicals manufacturers and exporters organized by the European Chemical Industry Council (CEFIC) visited the Turkish Ministry of Environment and Forestry (MOEF) in February to ask for more time to comply with its By-Law on Inventory and Control of Chemicals, which was first published at the end of 2008. This was amended in November 2009 to extend the deadline for compliance to June 30, 2010, but even this was considered too onerous for EU companies who are struggling to comply with a major Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) deadline for this year.

Speaking at ChemCon Europe in Prague in March, Eylem Öslem Nalbantoĝlu, MOEF, noted that the government was considering two amendments to the law to make it easier for EU-based companies with operations in Turkey to comply. One is an extension of the compliance deadline to March 30, 2011, and the other is the ability to establish a “legal trusty” in Turkey to file registrations on behalf of importers.

Ms. Nalbantoĝlu has since confirmed that MOEF has prepared a draft revised version of the By-law to include these two amendments, which has been sent to stakeholders, including public authorities, non-governmental organizations, and industry, for comment. If this process goes smoothly, an official amendment is likely to be published within two months.

The By-Law and Its Aims

The By-law seeks to establish a first inventory of the chemicals manufactured in and imported into Turkey. It applies to manufacturers and importers of substances on their own or in preparations who introduced the substances in Turkey in the three years up to December 26, 2008. Registration of such chemicals is required according to tonnage bands of 1-1,000 tpa and over 1,000 tpa. Chemicals newly produced or imported since that date must be registered within 14 months according to the amendment published in November 2009.

The By-law is part of a suite of changes planned by the Turkish government as it proceeds with accession talks to join the EU. Discussions on the environmental chapter of the accession deal were started on December 21, 2009.

Turkey already takes part in meetings of the EU’s Competent Authorities for REACH and Classification and Labeling (CARACAL) and is part of the REACH Helpdesk Correspondents’ Network (REHCORN) EU helpdesks for the REACH and CLP regulations. Turkey has established an industry REACH helpdesk and plans to establish a national helpdesk within MOEF. A REACH portal has also been established, which is available online.

A REACH Advisory Group is planning several projects this year to assess the impact of REACH implementation in Turkey while at the same time raising awareness and preparing companies for implementation of both REACH and CLP.