Chemical Watch Forum

Ian Sawyer · January 5

I understand Turkey published a list of chemicals in Dec 2011 that comprise their new Inventory. What is not clear to me is what obligations importers have for chemicals that are on the list and hence have already been notified.<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />

Does anyone know if an individual notification is required for each importer, or can other importers 'rely' on the notification of the first notifier?

With thanks.

Ian

Dieter Drohmann · January 21

Dear Lan,

According to the legal Regulation Chemical Inventory and Control of Chemicals Article 7/Article 8 every importer must submit all neccassary informations.

Updating of the reported information is regulated in article 11 as followed:

(1) Manufacturers and importers who have submitted information on a substance shall update the information forwarded to the Ministry in the following cases within 1 month:

a) New uses of the substance which substantially change the type, form, magnitude or duration of exposure of man or the environment to the substance;

b) New data obtained on the physico-chemical properties, toxicological or ecotoxicological effects where this is likely to be relevant to the evaluation of the potential risk presented by the substance;
and in c, d, 2, 3

regards Neslihan,
n.altinbas@chemservice-group.com

Melih Babayigit · February 8

Dear Ian,<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />

As you mentioned, Turkish MoEU has published
both HPV and LPV inventories for Turkey.

Any substance being listed on the inventory
doesnt provide any benefit to another importer that imports the same substance who
havent notified to the inventory. In general logic, it is similar to CLP notifications,
as only the one can benefit who made the notification.

The inventories published only announces what
had been received by the authority during the notification period ended by
31.03.2011. Also provides an opportunity to re-check to the companies if the
substance thay had notified is listed or not. As a consultant in Turkey I would
like to express that both lists are not final lists and there are many
substances not listed on the inventory even if they were succesfully notified.
As you will realize the list is EC number based and there is very few
substances with out an EC number which is indeed not the real case. Also there
are 44 substances listed on the inventory that are identified as exempted
substances on the Annex of the regulation. I assume that identifies the need
for a fix on the published list for LPV.

I
hope that helps. If you may need any further assistance please dont hesitate to
contact.

Kind Regards

melih@crad.com.tr
Melih Babayigit

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