By Patricia Manteghi
Turkish CLP regulation has been published by the Ministry of Environment and Urbanization on December 11, 2013 through the Official Gazette number 28848 (repeated).
This regulation will harmonize the former CLP (2008) regulation with the EU CLP regulation, in full, by June 1, 2016.
According to the harmonized CLP regulation, the deadline for Classification, Labelling & Packaging is June 1, 2015 for substances and June 1, 2016 for mixtures.
From June 1, 2015 until June 1, 2016, substances should be classified according to both CLP 2008 and CLP harmonized, but they should be labelled and packaged according to the CLP harmonized regulation.
Substances and preparations classified according to the CLP 2008 regulation before June 1, 2015 do not require relabeling and repackaging in accordance with the CLP harmonized regulation until January 1, 2017.
Substances and preparations classified according to the CLP 2008 regulation before June 1, 2016 do not require relabeling and repackaging according to CLP harmonized regulation until June 1, 2018.
For substances classified according to CLP 2008 before June 1, 2015 and for mixtures before June 1, 2016, importers, manufacturers as well as downstream users can reclassify using the conversion table in Annex 7 of CLP harmonized regulation.
Manufacturers and importers have to notify substances placed on the market before June 1, 2015 either on their own or in a preparation to the Turkish C&L inventory from June 1, 2014 to June 1, 2015, and for substances which are placed on the market after June 1, 2015 within one month to the C&L inventory.
According to Article 41 of the regulation, Manufacturers & Importers, importing substances on their own or as a mixture to Turkey, may cover the C&L notifications through an appointed legal representative in Turkey.
According to Article 41 of the regulation, the following information should be submitted to the C&L inventory either individually or as groups to the Ministry of Environment:
- Name, address, telephone/fax number or e-mail address of the notifier responsible for placing the substance on the market;
- Contact person;
- Place of the manufacturing;
- Substance identity as specified on Art. 39;
- Classification of the substance according with Art. 15;
- The reason, if the substance is not classified according to the regulation, either due to lack of data or insufficient data for classification;
- According to Art. 12, specific concentration limit values or M factors, if applicable, according to table 11;
- Labeling data and hazard statements.