Turkey Introduces Regulations on POP Chemicals
• Prohibit their manufacture, sale, distribution or use
• Eliminate or restrict their use
• Minimize their emission
• Manage their waste
To cover this, the regulation includes seven annexes for the management of POP chemicals:
• Annex 1 ‘Prohibited substances list
• Annex 2 ‘Restricted on its own, in mixtures or articles’
• Annex 4 ‘List of substances subject to waste management’
• Annex 5 ‘Waste management’
• Annexes 6 and 7 ‘Notification forms’
Representative restrictions include:
• Tetrabromodiphenyl ether - ≤ 10 mg/kg in substances, mixtures, articles or parts thereof
• Pentabromodiphenyl ether - as above
• Hexabromodiphenyl ether - as above
• Heptabromodiphenyl ether - as above
• Decabromodiphenyl ether - as above
• Perfluorooctane sulfonic acid and its derivatives (PFOS) –
o ≤ 0.001% in substances or mixtures
o < 0.1% in semi-finished products or articles, or parts thereof
o < 1 μg/m² in coated textiles or materials
• Hexabromocyclododecane (HBCDD) and its main isomers (-, - and -HBCDD) –
o ≤ 100 mg/kg in substances, mixtures, articles or parts thereof
• Short chain chlorinated paraffins (C10-C13, SCCP) –
o < 1% in substances or mixtures
o < 0.15% in articles
Stakeholders should also be aware that the ethers (tetrabromodiphenyl, pentabromodiphenyl, hexabromodiphenyl, heptabromodiphenyl, decabromodiphenyl) are exempt in electrical and electronic equipment under Number 28300 of May 22, 2012 and must be below 0.1% in recycled materials.
Published on November 14, 2018, the new law broadly mirrors the European Union’s Regulation (EC) 850/2004 for POP chemicals. Annexes 1 to 5 contain many of the same POP chemicals and the scope and requirements are largely similar.
Stakeholders should be aware Turkey has also listed the following chemicals under its POP legislation:
• Dicofol – a pesticide used in agriculture (prohibited under Annex 1)
• Decabromodiphenyl ether – a commercial mixture of Deca-BDE that is used as a flame retardant in a wide variety of applications (adhesives, coatings, inks, plastics, textiles and sealants). It is restricted under Annex 2 and is a chemical listed under Annex A (elimination) in the Stockholm Convention
The approach to Deca-BDE differs between the European Union and Turkey. In the EU it is restricted under entry 67 to Annex XVII of REACH, which is not the same in scope and requirements to Turkey’s POP legislation.
Published in the Resmi Gazete on November 14, 2018, as Number 30595, the legislation has two effective dates. The full POP legislation came into effect on November 14, 2018, except for the prohibited POP chemicals listed in Annex 1 that are in articles and restricted POP chemicals listed in Annex 2 that are in articles. For these, the effective date is May 14, 2019.
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