Haluk Erceber Shares Views and Comments on KKDİK

Haluk Erceber, Chairman of the Board of Turkey Chemical Manufacturers Association (TKSD), answered our questions and shared his views and comments on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).

The Regulation on Amendments to the Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals was published in the last days of 2023 and the deadline was extended. How do you think the chemical industry should proceed now, could you share your views and suggestions?
REACH Regulation was updated with the Regulation dated 23 December 2023 and numbered 32408 regarding registration deadlines and some other changes. In the new period, we see registration deadlines as 2026, 2028 and 2030 depending on tonnage and hazard classes. Turkey's Chemical Industry with its 16 sub-sectors should work proactively on this matter. The date 31 December 2026 can be considered as a milestone and is tomorrow. The phased transition process linked to tonnage can facilitate but not guarantee the emergence of leaders. Therefore, under the umbrella of TOBB and with all relevant Non-Governmental Organizations, data cost-sharing should be pursued as a unified body in line with EU-based consortia at reasonable prices, and procedures and principles should be determined following consultation with the Ministry of Environment, Urbanisation and Climate Change. Companies should not wait until the last day to register. Companies that register as early as possible will not be affected by potential data cost increases.

What do you consider the most important issues regarding REACH, how can these problems be overcome, could you comment?
At the forefront of the problems, we can point to the non-emergence of lead registrants. High data costs, insufficient information sharing due to competition, lack of knowledge and financing regarding SMEs and micro-enterprises becoming joint registrants are other problems we can list. Beyond these, EU sanctions on Russia and the related concerns of data holders in the EU regarding data sharing are also hampering the process. While the phased transition linked to tonnage will trigger the emergence of lead companies, it will not guarantee it. Companies may not have sufficient information about who to contact, how and in what manner to obtain data. In this context, it may be considered to establish a support unit within TOBB under the new regulation for data acquisition. SMEs' information deficiencies can be addressed by following the trainings given within associations on REACH regulations. As Turkey Chemical Manufacturers Association (TKSD), within the Chemical Management Platform established under our association in 2019, we share the latest information on all developing global regulations, particularly REACH/REACH, with our members at various intervals. Regarding Russian sanctions, it can be said that the problem can only be solved through bureaucratic channels, and individual company initiatives will not produce positive results.

What do you think will be the impact of REACH on our commercial relations with developed countries, particularly Europe and North America, could you evaluate it from a short and long-term perspective?
The EU is Turkey's largest trading partner. Half of our imports and exports fall within the EU scope. Therefore, conformity with the REACH Regulation, harmonised from the EU REACH Regulation, is of vital importance for our industry. The REACH Regulation, in addition to its primary objective of ensuring high levels of protection of human health and the environment, also incorporates the principle of encouraging alternative methods for evaluating the hazards of substances and thus promoting competition and innovation. Beyond the legal obligation of registrations carried out within the scope of the REACH regulation, innovative products developed thanks to its contribution to sustainable chemical management provide competitive advantages against rivals. From this perspective, full compliance with the regulation is of vital importance for creating an innovation culture in the Turkish Chemical Industry, enabling it to compete with the entire world and strengthening commercial relations with the EU. While all this is happening, new developments are being closely monitored. The Chemicals Strategy for Sustainability (REACH 2.0), one of the main policy initiatives of the European Green Deal, is taking chemical management to a different dimension. If these changes cannot be adapted to, significant disruptions may be seen in our international trade.