You can click the link below to access the Turkish PIC Regulation:
Turkish PIC Regulation (Regulation on the Export and Import of Certain Hazardous Chemicals)
Does the PIC Regulation Apply in Türkiye?
The PIC Regulation, or the Prior Informed Consent Regulation (EU) No 649/2012, implements the Rotterdam Convention on the Prior Informed Consent Procedure. For the purpose of incorporating this Regulation into Turkish legislation, the Ministry published the “Regulation on the Export and Import of Certain Hazardous Chemicals” in Official Gazette No 32087.
What Are the Requirements of This Regulation?
The obligations specified by the Ministry of Environment and Urbanisation of the Republic of Türkiye are as follows:
- Export notification: When designated hazardous chemicals are to be exported, a notification must be submitted to the Ministry once a year, no later than 35 days before the first export date.
- Transit notifications: If a chemical listed in Annex 2 to the Regulation on the Export and Import of Certain Hazardous Chemicals is to be transported in transit through the territory of a Party listed in Annex 7, the Ministry must be informed no later than 30 days before the first transit movement and no later than eight days before each subsequent transit movement.
- Packaging and labelling: Chemicals must must comply with the applicable packaging and labelling requirements under the SEA Regulation.
- Safety Data Sheets (SDSs): Safety Data Sheets must be prepared in accordance with KKDIK for the chemicals in the official language of the relevant country.
- Letter of Conformity: Exporters subject to obligations under the Regulation must submit the Letter of Conformity to the customs authority.
- Electronic submissions: Where deemed necessary by the Ministry, notifications must be submitted through the e-PIC system available within the e-ÇŞB platform.
- Annual reporting: Exporters and importers of chemicals covered by the Regulation must report the quantities exported or imported during the previous calendar year to the Ministry by 31 March.
Who Must Comply?
- Exporters: All natural and legal persons and partnerships that export or intend to export hazardous chemicals and certain mixtures containing such chemicals within the scope of the Regulation
- Importers: Natural or legal persons and other relevant entities importing hazardous chemicals and mixtures within the scope of the Regulation
- Competent authorities: Competent authorities that manage and supervise the administrative processes under the Regulation and take decisions within their respective areas of responsibility
Which Chemicals Are Listed?
Under the Regulation, chemicals are separated into three principal lists according to their regulatory status and the applicable international conventions:
- Annex 1 List (Banned or severely restricted chemicals): These are chemicals that have been banned or severely restricted under legislation by the Ministry and the relevant authorities. Substances that are subject to a ban or severe restriction in Türkiye and in at least one of the categories of plant protection products, biocidal products or industrial chemicals are included in this list.
- Annex 2 List (Chemicals subject to the PIC procedure): These are substances that are subject to the prior informed consent (PIC) procedure under the Rotterdam Convention and are included in the Convention’s list of chemicals subject to the PIC procedure.
- Annex 6 List (Chemicals subject to an export ban): These are chemicals whose export outside the Customs Territory of Türkiye is completely prohibited. Chemicals covered by the prohibition provisions to the Stockholm Convention on Persistent Organic Pollutants are included to this list.
The Regulation covers specified hazardous chemicals in plant protection products, biocidal products and industrial chemicals that are manufactured as substances or in mixtures, or occur naturally, provided that they do not contain living organisms.
What Happens in the Event of Non-Compliance?
Compliance with the PIC Regulation in Türkiye is monitored by the Ministry of Environment, Urbanisation and Climate Change. Administrative sanctions are imposed on those who violate the requirements of the Regulation. Therefore, companies involved in the export or import of chemicals covered by the Regulation must ensure compliance with the applicable requirements.
Receive Support from Chemleg for Compliance with the PIC Regulation in Türkiye
Through its PIC notification services, Chemleg can help you comply with the PIC Regulation in Türkiye.
If you have any questions, complete the form now to arrange a consultation with our experts.
