İlayda Kanat
Chemist
Chemical Assessment Specialist
Doruksistem A.Ş.
Polyurethanes, KKDIK and Product Safety
Polyurethanes are among the polymer systems used in many applications, especially in the footwear sector, thanks to properties such as lightness, durability and versatility. Shoe sole systems, elastomeric structures, foam applications, adhesives, coating systems, sealants and various technical parts clearly show how widely polyurethanes are used across different sectors. This broad range of use makes polyurethanes a subject that deserves careful attention not only in terms of technical performance, but also in relation to chemical content, product safety and increasingly visible sustainability expectations.
This article discusses how different forms of polyurethane use affect regulatory assessment, which obligations come to the fore under KKDIK, why the product safety approach goes beyond the limits of chemical compliance, and how current expectations for the European Union market are reflected in the sector.
The different forms of polyurethane use and their impact on regulatory assessment
In Turkey, the main framework governing chemicals has been established by the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (KKDIK). Issues such as placing products on the market, the responsibilities of economic operators, market surveillance and corrective measures are addressed under product safety legislation. In Turkey, the general framework for product safety has been shaped by Law No. 7223 on Product Safety and Technical Regulations, and the overall product safety approach has been supported by related secondary legislation. For companies operating in the European Union market, the product safety and sustainable product approach opens up a broader area of assessment than chemical compliance alone.
The different forms in which polyurethanes are used make it difficult to assess these materials within a single, uniform regulatory structure. The main reason is that systems capable of responding to different performance needs can be developed within the same family of materials. In the footwear sector, sole systems, elastomeric structures and comfort-oriented foam applications come to the fore; in other areas, adhesives, coatings, sealants and elastomer applications also stand out. This diversity makes it necessary to evaluate polyurethanes as a group of systems designed for different intended uses.
From the perspective of the footwear sector in particular, regulatory assessment often presents a more complex picture than the examination of a single c. The main reason is that footwear is a multi-component product. Polyurethane sole systems, foam structures, adhesives, coatings and various auxiliary materials come together within the same product; this creates a more layered structure for both chemical content management and product safety assessment. For this reason, when assessing the suitability of a polyurethane-based component in the footwear sector, the material’s own properties, its function within the product, its relationship with other components and the conditions of end use should all be considered together.
The main point here is that the broad range of polyurethane applications directly affects regulatory assessment. A product belonging to the same family of materials may be placed on the market as a mixture in one case and become part of an article in another. In multi-component products that reach consumers directly, it becomes even more important to position polyurethane-based materials within the correct regulatory framework. For this reason, one of the first key steps in polyurethane systems is to determine correctly where the product stands within the scope of KKDIK.
Assessment of polyurethanes under KKDIK
When assessing polyurethane products under KKDIK, it is not enough to rely only on the definition of “polymer.” KKDIK is the main legislation governing the registration, evaluation, authorisation and restriction processes for chemical substances. Within this framework, polyurethane systems should be considered not only in terms of their technical properties, but also in terms of how their constituent components are positioned from a regulatory perspective.
Within this scope, polymers themselves are not subject to direct registration obligations. By contrast, under certain conditions, registration obligations may arise for monomers that have not previously been registered by an actor in the supply chain, as well as for other substances chemically bound to the polymer. A registration obligation may arise if the polymer contains such substances at 2% by weight or more and if the total amount of these substances is 1 tonne per year or above. This shows that polyurethane systems should be assessed not merely by product name, but together with their component structure and tonnage information.
This point is also important for the polyurethane sector, because in practice the term “polymer” is sometimes interpreted as meaning that no obligations exist. However, even though registration provisions do not apply to polymers themselves, the registration approach remains important with regard to the monomers forming the polymer and other substances chemically bound to it, provided the relevant conditions are met. For this reason, in polyurethane systems, the regulatory status of the components used should be assessed separately alongside their technical functions.
Another critical issue in the assessment of polyurethane products is to determine correctly whether the product is placed on the market as mixture or article. In practice, two-component polyurethane systems, prepolymer-based formulations, adhesives or coating systems are often treated as mixtures, whereas shoe soles, foam parts, panels and similar final products may qualify as articles. This distinction is not merely terminological; the obligations to be applied also vary depending on the way the product is placed on the market. In products that qualify as articles, substances intended to be released under normal or reasonably foreseeable conditions of use may require separate assessment under certain tonnage and registration conditions. Therefore, for companies active in the polyurethane field, the first step is to define each product in the portfolio correctly within the framework of its intended use and form of supply.
In summary, the assessment of polyurethane products under KKDIK should be carried out by considering together the product’s composition, form of supply, intended use and position in the supply chain. From this perspective, regulatory compliance in polyurethane systems stands out as one of the key issues that should be considered together with technical performance assessment.
Information management, the supply chain and the registration approach
Regulatory compliance in polyurethane products cannot be regarded as an issue limited to registration obligations; information management and supply chain communication also lie at the centre of this process. Information management plays a decisive role in ensuring chemical safety. Safety Data Sheets are among the main sources of information on the safe use of chemical substances and mixtures, and for this reason they must be prepared accurately, kept up to date and aligned with the legislation. According to the Ministry’s announcements, from the period after 31 December 2023, SDSs have been prepared under KKDIK by Chemical Assessment Specialist certified in accordance with Annex-18. This makes the availability of current and compliant SDSs for polyurethane-based substances and mixtures one of the basic elements of accurate information flow throughout the supply chain.
In the polyurethane sector, information management goes beyond documentation. It is also directly related to maintaining data quality throughout the supply chain. In systems involving numerous inputs such as polyols, isocyanates, additives, catalysts, chain extenders, solvents and other auxiliary components, the correct transfer of regulatory information for each component carries particular importance. Composition information obtained from suppliers, classification data, restriction status, safe use conditions and the currency of documentation affect the process extending from the initial supply stage to the placing of the final product on the market. For this reason, regulatory compliance in the polyurethane field requires the coordinated and orderly management of both technical formulation and regulatory information.
The practical aspect of the registration process brings with it the need to assess product portfolios together with component information in the polyurethane sector. Companies need to examine the substances in their portfolios not only in terms of technical function, but also in terms of registration obligations. Given different supply structures, import scenarios and forms of use, it is clear that the same registration method will not be suitable for every substance. For this reason, the registration process should be addressed together with data management and supply chain communication. Such an approach will make it easier for companies operating in the polyurethane sector to shape their registration strategy on a substance-by-substance basis and in line with their own commercial structure.
The product safety framework and expectations for the EU market
Compliance assessment for polyurethane products should be addressed not only in terms of chemical safety, but also in terms of product safety. In Turkey, the main framework in the field of product safety has been established by Law No. 7223 on Product Safety and Technical Regulations. The purpose of this Law is to ensure that products are safe and comply with the relevant technical regulations, and to determine the principles of market surveillance and inspection, as well as the duties of competent authorities and the obligations of economic operators. This structure clearly shows that, in consumer products containing polyurethane, chemical compliance and product safety form two separate but connected areas of assessment.
This framework is important for the polyurethane sector not only in relation to products placed on the domestic market, but also for products subject to foreign trade. The Regulation on Technical Regulations in Foreign Trade covers the technical regulations applicable to products subject to foreign trade, import and export inspections, the duties and responsibilities of the authorities carrying out inspections, the responsibilities of importers and exporters, the measures to be taken and the sanctions to be applied. For this reason, product safety should not be seen by exporting companies as an issue limited to compliance with the legislation of the target market. It is also part of the conformity assessment process that must be taken into account at the point of exit from Turkey.
TAREKS, the Risk-Based Control System for Foreign Trade used in export inspections, constitutes the application infrastructure through which inspections, conformity and permit procedures are carried out electronically and on a risk basis under product safety legislation and technical regulations. In final consumer products such as footwear, this structure clearly shows that the product safety approach is not confined to the chemical components used in the formulation. Documentation, traceability, conformity information and, where necessary, the capacity to take corrective action also form part of the same area of assessment.
For polyurethane-based products placed on the European Union market, the general product safety approach presents a more visible and more comprehensive framework. The General Product Safety Regulation (GPSR) applied in the European Union has updated the general safety framework for non-food consumer products. With this regulation, traceability, the visibility of product safety information in online sales channels, the responsibilities of economic operators, and corrective measures and recall processes for dangerous products have become more prominent. As a result, assessment in consumer products containing polyurethane has expanded beyond the level of chemical content; the accessibility of product information, supply chain responsibility and post-market follow-up processes have also come more strongly to the fore.
Another important issue within the product safety framework is market surveillance and corrective action processes. When unsafe products are identified on the market, the consequences may go beyond technical non-compliance and also affect distribution chain management and commercial continuity. For this reason, compliance for consumer products containing polyurethane should not be regarded as a control process completed at the moment the product is placed on the market; it should be treated as an area of responsibility that must be monitored throughout the product life cycle. The Safety Gate system in the EU also serves to ensure the rapid exchange between competent authorities of measures taken in relation to dangerous non-food products and shows how visible product safety risks have become.
Sustainability, data transparency and overall assessment
The dimensions of sustainability and data transparency are increasingly shaping next-generation compliance expectations for products containing polyurethane. The Ecodesign for Sustainable Products Regulation has established a broader framework for products in the EU. The Regulation creates the legal basis for setting ecodesign requirements for sustainable products and brings issues such as durability, reuse, reparability, recyclability, resource efficiency and information transparency to the forefront. In this respect, ESPR extends beyond material selection for products containing polyurethane and also affects expectations regarding product design and the management of product information.
The important point here is not to read ESPR as if it were a single text that already imposes the same technical obligations on every product. The Regulation does not provide ready-made rules at the same level of detail for all product groups; instead, it establishes the framework within which product-specific requirements will be shaped through subsequent regulations. For this reason, for products containing polyurethane, ESPR should not be viewed as a completed, one-size-fits-all list of obligations, but rather as a regulatory direction that raises expectations in terms of data transparency, design approach and traceability in the near future.
The digital product passport is also one of the notable elements of this framework; however, which information will be required for which product groups will become clear through subsequent product-specific regulations. From this perspective, the digital product passport stands out not only as a new field of information for companies, but also as a preparation agenda that requires product data to be kept more regularly, more traceably and more up to date. Accordingly, strengthening data quality, product information and traceability infrastructure is becoming a more visible need for products containing polyurethane.
In conclusion, regulatory compliance in the polyurethane sector now appears as a multi-layered area of assessment.
In the assessment of polyurethane products, the product’s form of supply, intended use, position in the supply chain and target market should be considered together with its chemical composition. While registration obligations under KKDIK, the distinction between mixture and article, and the requirements related to Safety Data Sheets form the basis of this process, the product safety framework in Turkey, technical regulations in foreign trade, and expectations arising from GPSR and ESPR for products intended for the EU market are also becoming increasingly decisive. This turns regulatory compliance into a strategic issue for companies operating in the polyurethane sector in terms of product management, export continuity and market access.
Within this framework, it is important for companies to assess polyurethane systems in relation to regulatory obligations together with performance criteria. Correct component-based analysis, timely determination of the registration approach, sound management of information flow throughout the supply chain, attention to product safety expectations and strengthening of traceability infrastructure will become even more decisive in the coming period. Safe and sustainable production requires the combined consideration of chemical legislation, product safety, foreign trade conformity and the ecodesign approach.
References
Ministry of Environment, Urbanization and Climate Change. Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (KKDIK). Official Gazette, 23 December 2017, No. 30279 (Duplicate Issue).
Ministry of Environment, Urbanization and Climate Change, Chemicals Help Desk. Announcement on Safety Data Sheets.
Republic of Turkey. Law No. 7223 on Product Safety and Technical Regulations. Official Gazette, 12 March 2020, No. 31066.
Republic of Turkey. General Product Safety Regulation. Official Gazette, 11 March 2021, No. 31420.
Ministry of Trade of the Republic of Turkey. TAREKS – Risk-Based Control System for Foreign Trade.
European Parliament and the Council of the European Union. Regulation (EU) 2023/988 on General Product Safety. Official Journal of the European Union, 23 May 2023.
European Parliament and the Council of the European Union. Regulation (EU) 2024/1781 Establishing a Framework for the Setting of Ecodesign Requirements for Sustainable Products. Official Journal of the European Union, 28 June 2024.
European Commission. Safety Gate: The EU Rapid Alert System for Dangerous Non-Food Products.
