Chemical Watch Forum

As a Turkish Regulatory consultant I had read the article authored by Marcus Navin-Jones published on November 2010 mothly briefing I had noted some misinterpretations of Turkish C.I.C.R. and noted them with their corrections below to prevent an ambiguity on the issue.

CW Article : (although monomers in polymers are not exempt and therefore must be notified).

There is no such information provided by the legal text and it has been discussed with MoEF and been indicated that it is not required to notify reacted monomers.

CW Article : However, the Bylaw was amended this time last year (November 2009) and now specifically addresses this point. The changes allow certain non-Turkish entities to appoint a Turkish-based entity (a so-called ‘representative’) to notify on their behalf.

This was added to the legal text by the amendment published on 23th of May 2010.

CW Article : The requirement to notify new substances came into effect as of 1 January 2010. Therefore, if an entity imported a new substance into Turkey in January of this year, that entity has just two months left to submit its notification.

The legal text clearly defines as Article 7 Subparagraph 2 : 12 months plus 3 months to notify any substance either manufactured or imported to be notified from the first date of import.

CW Article : The ministry is required to publish a list of all substances manufactured or imported in quantities above 1,000 tonnes/year. The exact data submitted during the notification procedure to be made publicly available by the ministry is unclear.

On the legal text it is texted as :
Article 7 sub paragraph (5): Ministry will publish a list including substances produced on its own or imported on its own
or in a preparation, thousand tonnes or more per year. So it is not stated as all data but only as list of substances .

Best Regards
Melih Babayigit / CRAD Turkiye