What is a certified chemical assessment expert (KDU)?

Contents

Who is a KDU, and what do they do?
Before and after 2024: what happened to the "GBF preparer" certificate?
How does someone become a KDU?
For companies: a KDU on staff or an external service?
Can software replace a KDU?
Frequently asked questions
Sources

In short: a Kimyasal Değerlendirme Uzmanı (KDU), a certified chemical assessment expert, is a person certified under Annex 18 of the KKDİK Regulation (often called "Turkish REACH") and authorised to assess chemicals. Since 1 January 2024, a safety data sheet in Türkiye (GBF, Güvenlik Bilgi Formu) may be prepared only by a KDU (KKDİK Article 27/1). A KDU also takes part in KKDİK work such as the chemical safety assessment and report.

Who is a KDU, and what do they do?

KDU is a title introduced by KKDİK, the Turkish adaptation of the EU REACH system (Regulation (EC) No 1907/2006). The regulation requires that the GBF the supplier provides to the recipient be "compiled in accordance with Annex 2 and prepared by a chemical assessment expert certified under Annex 18" (Article 27/1). The main tasks of a KDU:

Preparing and updating safety data sheets (according to Annex 2, 16 sections).
Preparing the chemical safety assessment and report (KGD/KGR): for substances subject to registration.
Contributing to the registration dossier: a statement that certain information in the KKDİK registration dossier has been reviewed by a KDU is required.

When preparing a GBF, the KDU's job is less about writing the form and more about the accuracy of the data: verifying the classification and concentration limits of the components, classifying the mixture under the rules of the SEA Regulation (the Turkish counterpart of the EU CLP Regulation), selecting toxicological and ecotoxicological data, and determining exposure limit values and the transport class.

Before and after 2024: what happened to the "GBF preparer" certificate?

Under the old system, GBFs were prepared according to the Safety Data Sheets Regulation of 13/12/2014 by people holding a "GBF preparer" certificate. This option ended on 31/12/2023; since 1 January 2024 the only basis is KKDİK Annex 2 and the only authorised person is a KDU. Forms prepared under the old certificate and not yet updated must be re-prepared by a KDU according to KKDİK Annex 2 at the next update.

How does someone become a KDU?

The certification requirements are set out in KKDİK Annex 18. The general framework:

Education: a degree from one of the relevant undergraduate programmes listed in Annex 18 (chemistry and related science/engineering fields).
Training: KDU training at a training body authorised by the Ministry.
Exam and certificate: passing the exam of a certification body authorised by the Ministry; the certificate is issued for a limited period and renewed.

For the training duration, exam and renewal conditions, the current and binding sources are the Chemicals Helpdesk of the Ministry of Environment, Urbanisation and Climate Change and the programme pages of the authorised certification bodies; because the conditions can change, we do not give figures in this article.

For companies: a KDU on staff or an external service?

The obligation to have the GBF prepared lies with the supplier; the KDU does not have to be employed by the company. There are two common approaches:

	KDU on staff	Consultancy / external service
Suitable when	Many products, frequent formulation changes	Few products, infrequent updates
Advantage	Knows the product and production; fast updates	Low start-up cost; access to several experts
Watch out for	The validity and renewal of the certificate must be tracked	Formulation changes must be reported to the consultant in time

In both cases the GBF shows the name and certificate details of the preparing KDU; common practice is to give this in Section 16, together with the certificate number and expiry date. When you check a GBF as a recipient, look for this information and check that the certificate is valid.

Can software replace a KDU?

No. The regulation defines the preparer as a person; the signature and responsibility lie with the KDU. The job of software is to speed up the part that takes up the KDU's time: collecting component data (ECHA CHEM records), doing the calculation with the CLP summation method, selecting P statements, and filling the 16 sections into the template. Chemoris does this preparation work and shows the reasoning behind every result; the KDU checks the results and corrects them manually where needed. The calculation logic is explained in Mixture classification under CLP.

Frequently asked questions

Can a chemist without a KDU certificate prepare a GBF?

No. Since 1 January 2024, the GBF provided by the supplier must be prepared by a KDU certified under Annex 18. A chemist without the certificate can work on data collection and the draft; the KDU prepares the form and takes responsibility for it.

Is a KDU also needed for the GBF of an imported product?

Yes. For a product placed on the market in Türkiye, the Turkish GBF is prepared according to KKDİK Annex 2 and by a KDU. The foreign supplier's SDS is a data source but is not enough on its own.

If a KDU's certificate expires, do the GBFs they prepared become invalid?

The regulation has no explicit provision on this. The safe approach is to have updates and new forms done by a KDU with a valid certificate.

Sources

KKDİK Regulation (23/06/2017, Official Gazette No. 30105), Article 27/1 and Annex 18 (text on mevzuat.gov.tr).
Regulation on Safety Data Sheets for Hazardous Substances and Mixtures (13/12/2014, Official Gazette No. 29204) — until 31/12/2023.
Ministry of Environment, Urbanisation and Climate Change of the Republic of Türkiye — Chemicals Helpdesk (kimyasallar.csb.gov.tr).