How to prepare a Turkish SDS: the 16 sections one by one

Contents

What is a GBF, and why does it exist?
General rules of Annex 2
16 sections: what goes in, and where does the data come from?
Consistency between sections: the most overlooked part
5 common mistakes
Sources

In short: Since 1 January 2024, a GBF (Güvenlik Bilgi Formu, the Turkish safety data sheet) in Türkiye is prepared only according to Annex 2 of the KKDİK Regulation (often called "Turkish REACH") and by a certified Kimyasal Değerlendirme Uzmanı (KDU), a certified chemical assessment expert. The form has 16 sections, and no subsection is left empty. Most sections are not filled from a single source but from a combination of component data, the classification result and product-specific information.

What is a GBF, and why does it exist?

The safety data sheet (GBF in Turkish; SDS in English, formerly MSDS) is the standard document that tells the recipient about the hazards of a chemical substance or mixture and how to use it safely. According to KKDİK Annex 2, its purpose is to let users take the measures needed to protect human health, safety at the workplace and the environment. Employers also base much of their workplace risk assessment on this form.

Who must prepare it and when it must be given to the recipient is a separate topic; we cover it in GBF responsibility under KKDİK.

General rules of Annex 2

Before going into the sections, here are the rules that apply to the whole form and that most often cause problems in inspections (KKDİK Annex 2, Part A):

The language is plain and precise. Phrases such as "may be dangerous", "no health effects", "safe under most conditions of use" or "harmless", and phrases inconsistent with the classification, are not used (0.2.4).
Date and revision. The date of compilation is given on the first page. In an updated version the changes are indicated in Section 16; "Revision: (date)", the version/revision number and which version it replaces appear on the first page (0.2.5).
Page numbers. All pages, including annexes, are numbered and the total number of pages is shown (e.g. "page 1 of 7") (0.3.2).
No empty subsections. If information is not available or not applicable, the reason is stated (0.4).
The preparer is a competent person. The supplier ensures that the preparer receives appropriate training, including refresher training (0.2.3).

16 sections: what goes in, and where does the data come from?

Section	Content	Where does the data usually come from?
1. Identification of the substance/mixture and of the company	Product name, identified uses, supplier, emergency telephone number	Company and product information
2. Hazards identification	Classification, label elements (pictograms, signal word, H and P statements), other hazards	CLP/SEA classification of the mixture
3. Composition / information on ingredients	Identity of hazardous components (CAS, EC), concentration range, their classification	Formulation + C&L data of the components (e.g. the ECHA C&L Inventory)
4. First-aid measures	First aid by route of exposure, symptoms	Standard phrases linked to the classification
5. Firefighting measures	Suitable extinguishing media, combustion products, advice for firefighters	Physical hazards + product information
6. Accidental release measures	Personal precautions, environmental precautions, clean-up methods	Standard phrases linked to the classification
7. Handling and storage	Safe handling, storage conditions, incompatible materials	Product information + classification
8. Exposure controls / personal protection	Occupational exposure limit values, PPE, engineering controls	Component limit values + classification
9. Physical and chemical properties	Appearance, pH, flash point, density, solubility, etc.	The product's own measurements (laboratory)
10. Stability and reactivity	Reactivity, stability, conditions and materials to avoid	Product information + component data
11. Toxicological information	Acute toxicity, irritation, sensitisation, CMR, STOT, etc.	Registration dossier data of the components (e.g. ECHA REACH dossier summaries)
12. Ecological information	Aquatic toxicity, persistence, bioaccumulation, PBT/vPvB	Registration dossier data of the components
13. Disposal considerations	Waste treatment methods, packaging disposal	Standard phrases + waste legislation
14. Transport information	UN number, proper shipping name, class, packing group, environmental hazards	ADR mapping from the classification
15. Regulatory information	Product-specific legislation (KKDİK, SEA, restrictions), chemical safety assessment	List of legislation
16. Other information	Revision changes, abbreviations, sources, full text of the H statements in Sections 2 and 3, preparer	The preparing KDU

Consistency between sections: the most overlooked part

Most errors in a GBF do not come from a single section but from sections that do not match each other:

Section 2 ↔ 3: if a "Skin Corr. 1B" component is at 10% in Section 3 but the mixture appears only as "irritant" in Section 2, the summation calculation has not been done. We explain the calculation with an example in Mixture classification under CLP.
Section 2 ↔ 14: if the mixture is "Aquatic Chronic 1" (H410), the environmentally hazardous substance mark and a suitable UN number must be considered in Section 14.
Section 2 ↔ 4–8: if H314 (corrosive) applies, the first-aid, PPE and storage measures must be written accordingly; generic text is not enough.
Section 16: the full text of every H code in Sections 2 and 3 must appear here.

5 common mistakes

Translating the supplier's GBF (often in a foreign language) and changing the product name: if the mixture is different, the classification is different too.
Leaving subsections empty, or writing "no data" without stating the reason.
Not marking the sections changed in a revision and not updating the version information on the first page.
Referring to regulations that no longer apply (after 31.12.2023 a GBF is prepared only according to KKDİK Annex 2).
Using phrases such as "harmless" or "environmentally friendly" that Annex 2 explicitly prohibits.

A printable tick-off version of this check for all 16 sections: SDS checklist (16 sections).

Sources

KKDİK Regulation Annex 2, "Requirements for the Compilation of Safety Data Sheets" (Parts A and B).
SEA Regulation (Official Gazette No. 28848 of 11/12/2013), CLP Regulation (EC) No 1272/2008.
Ministry of Environment, Urbanisation and Climate Change of the Republic of Türkiye — Chemicals Helpdesk.

Codes in this article

Related codes

H and P statements related to this topic; each is explained in the glossary with its full wording, thresholds and label use.

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