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.
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.
According to the Regulation;
Classification and Labeling Inventory
ARTICLE 40- (1) Provisions related to the classification and labeling inventory included in the Article 41, 42 and 43 shall apply to:
a) Substances specified in the first, second, third and fourth provisions of Annex 8,
b) Substances within the scope of Article 2 which meet the criteria for classification as hazardous and are placed on the market either on their own or in a mixture above the concentration limits specified in this By-Law or By-law on the Classification, Packaging and Labeling of Dangerous Substances and Preparations, where relevant, which results in the classification of the mixture as hazardous.
Obligation to Notify
ARTICLE 41-(1) Any manufacturer or importer, or group of manufacturers or importers, who places on the market a substance referred to in Article 40, shall submit the following information in order for it to be included in the inventory referred to in Article 43, in the format that exists on the Competent Authority web site:
a) The following information about the notifier responsible for placing the substance on the market in self notification or each manufacturer or importer in joint submission;
1) Name, address, telephone number, fax number and e-mail address;
2) Contact person;
3) Location of the production;
b) The identity of the substance as specified in point (a) of Article 39(1);
c) The classification of the substance in accordance with Article 15;
ç) Where a substance has been classified in some but not all hazard classes or differentiations, an indication of whether this is due to lack of data, inconclusive data, or data which are conclusive although insufficient for classification;
d) Specific concentration limits or M-factors, where applicable, in accordance with Article 12 of this By-Law together with a justification using the relevant Parts of Annex 11;
e) The label elements specified in points (ç), (d) and (e) of Article 19(1) for the substance together with any supplemental hazard statements for the substance, determined in accordance with Article 27
(2) The information listed in paragraph one shall be updated and notified to the Competent Authority by the notifier(s) concerned when, pursuant to the review in Article 17, a decision to change the classification and labeling of the substance has been taken.
(3) Substances shall be notified in accordance with paragraph 1 within one month after their placing on the market.
(4) In the case of import of substances on their own or in a mixture; importer, on the point of being responsible for the obligation, may fulfill the obligations of importers under the scope of paragraph (1) (2) and (3), through a representative that is established in Turkey and appointed with an agreement determined by the natural or legal persons settled abroad.
Agreed Entries ,
ARTICLE 42- Where the notification in Article 41(1) results in different entries on the
inventory referred to in Article 43(1) for the same substance, the notifiers shall make every effort to come to an agreed entry to be included in the inventory. The notifiers shall inform the Competent Authority accordingly.
Establishing and Updating of the Classification and Labeling Inventory
ARTICLE 43- (1) The Competent Authority, shall establish and maintain a classification and labeling inventory in the form of a database and provide its persistence.
(2) Information in the inventory which corresponds to the information referred to in Part 1 of Annex 10 may be publicly accessible.
You can find the English Version of TR-CLP Regulation full text as linked in here.
Turkey SEA (CLP) Regulation Services
DorukSistem provides global 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.
*SEA : Abbreviation for CLP in Turkish