Regulation

Turkish SDS: consultant, software or an in-house KDU?

Three ways to prepare a GBF: a KDU on staff, an external KDU or consultancy, or a KDU plus software. A comparison table, when each makes sense and who stays responsible.

Updated: 4 min read

Contents
  1. The rule that does not change
  2. The three routes compared
  3. Which makes sense when?
  4. Where does Chemoris stand?
  5. Frequently asked questions
  6. Sources

In short: there are three ways to prepare a GBF (Turkish SDS) under KKDİK (Turkish REACH): employ a KDU (Chemical Assessment Expert) on staff, buy the service from an external KDU or consultancy, or speed the work up with software that a KDU uses. They are not mutually exclusive; which one fits depends on your number of products, how often you revise and your in-house expert capacity. The legal requirement is the same for all of them: the GBF is prepared by a KDU.

The rule that does not change

Since 1 January 2024, a GBF in Türkiye can only be prepared by a Chemical Assessment Expert (KDU) (KKDİK Article 27/1). This holds whichever route you choose. Software does not replace the KDU; consultancy is the KDU supplied from outside. Details: what is a KDU?

The three routes compared

RouteStrengthPoint to watch
KDU on staffAn expert who knows the product and the production and is reachable at every revision; continuous know-how.Fixed cost; capacity may be more than a company with few products needs.
External KDU / consultancyService as needed; expertise comes ready-made.Total cost and waiting time grow as the number of products and revisions grows; the flow of information depends on the company.
KDU + softwareRepetitive work (data collection, classification calculation, document generation) is automated; the expert focuses on the final check.You need to question the software's data source, reasoning and editability; the responsibility is still the KDU's.

We give no figures in the table: cost varies from company to company depending on the number of products, revision frequency and how the expert works.

Which makes sense when?

  • Few products, rare revisions: an external KDU is usually enough; if you want the GBF prepared with software, your KDU can use the tool.
  • Many products or frequent recipe changes: a tool that automates the repetitive work saves time for both the KDU and the company.
  • Export: if you need the language and format of the target country (for example REACH Annex II in the EU), a tool with multilingual output reduces the workload. See SDS for export to the EU.
  • Consultancy firms: when managing the products of several clients, saved forms in a single panel and quick revision make the difference.

Where does Chemoris stand?

Chemoris is not a consultancy service; it is a tool used by KDUs and companies. It pulls ECHA CHEM data, classifies the mixture with CLP rules and shows the reasoning, and delivers the 16-section GBF as an editable Word document. All fields are editable; the final check and the responsibility stay with the user. New accounts get 1 free GBF credit, no credit card needed. For the options see the pricing page; to see the method, read how to prepare a Turkish SDS.

Frequently asked questions

Does using software reduce the KDU's responsibility?

No. The supplier and the KDU who prepares the form are responsible for its content; the software is a tool. The classification and the text must be checked by the expert.

If I have no KDU, can I prepare a GBF with software alone?

No; since 2024 the GBF must be prepared by a KDU. A company without a KDU must work with an external KDU; the KDU can use a tool such as Chemoris if they wish.

Can consultancy firms use software too?

Yes. Consultants can keep and revise the forms of several clients in a single panel; the responsibility still lies with the KDU providing the service.

Sources

  • KKDİK Regulation (23/06/2017, Official Gazette 30105), Article 27 and Annex 2 (text on mevzuat.gov.tr).
  • Regulation amending the KKDİK Regulation (23/12/2023, Official Gazette 32408).

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