Turkey has published the implementation of TR-CLP (SEA) in Turkish Official Gazette with number 28848 on 11 December 2013. As with the EU CLP Regulation, there will be a transition period prior to the regulation coming into force as of 1 June 2016.
Manufacturers and downstream users and/or importers of chemical substances have a legal obligation to classify and notify substances placed on the Turkish market.
Substance classification notification to the Turkish C&L inventory starts June 1st 2014 and ends June 1st 2015 for substances alone and in mixtures placed on the market before June 1st 2015. After 1st of June 2015, substances need to be notified to inventory within a month from the day of the first date of import or manufacturing.
For mixtures the CLP Classification & Labelling criteria obligation will apply as of 1st of June 2016. A 2 year transition period for the products that were placed on the market prior to deadline dates applies to labelling.
The obligations of chemical manufacturers and importers for classification, labeling and notifications are:
01/June/2014 - 1/June/2015 -
- Notification to the Turkish C&L inventory starting 1 June 2014 and ending 1 June 2015 for substances placed on the market, either on their own or in a mixture before 1 June 2015.
- Substances placed on the market after this date would have to be notified within one month
01/June/2015 - 1/June/2016 –
- Substances classification and labelling according to the new regulation is obligatory as of 1 June 2015 and for mixtures as of 1 June 2016; a two-year transition period for the products already on the market prior to this date will apply.
- A unique point in the Turkish CLP (SEA) implementation as defined in article 41 of the regulation, is for the protection of CBI in that exporters to Turkey may address their importers C&L notification obligations through a Turkish appointed Legal Representative.
You can find the Turkish TR-CLP Regulation text as linked in the file ENGLISH (not official) text as linked in the file.
Notification can only be conducted by a legal Turkish entity
Companies importing substances and mixtures into Turkey can cover the C&L notification obligation of their importing customers through an appointed Legal Representative. DORUK SISTEM also provides support to Turkish manufacturers and importers lacking expertise and or resources to notify classified substance.
DorukSistem will continue to provide regulatory expertise by helping companies exporting products to Turkey with identifying their TR-CLP (SEA) regulatory obligations, and will be preparing C&L notifications for submission to the Turkish Competent Authority (provided group notification will be permitted).
DorukSistem also offers full declaration support and a consulting strategy and training package to support companies in meeting the CLP (SEA) compliance requirements.
Turkish Chemical Regulation Services
DorukSistem’s experts can assist you step-by-step with the process of meeting all your obligations to comply with the Turkish Chemicals Regulation.
DorukSistem regulatory services include:
- Only Representative Services
- Strategy and consulting services
- Assessment of your company’s regulatory obligations
- Preparation of data requirements and documentation for notification (including determination of physicochemical, toxicological, and eco-toxicological characteristics of substances if required)
- Submission of notifications in the format required
- Liaison with Turkish authorities where required
- Act as 'Turkish Representative’ on the behalf of non-Turkish operators
- Regulatory corporate training
Please contact for further information you need and/or for DorukSistem Only Representative Services for Turkey.