The success of regulations protecting human health and the environment is possible with a feasible schedule that takes into account the production realities of the industry. Establishing the right balance in the KKDİK process will also be the key to protecting our sector's competitive power.
One of the topics that has increasingly taken up space on our industry's agenda recently is regulations regarding the management of chemicals. We all know the importance of regulations implemented to protect human health and the environment. On the other hand, we believe that implementing these regulations by considering our country's production structure and the current conditions of our industry is at least as important as the regulation itself. In this context, the current stage reached in the implementation process of the KKDİK Regulation, which closely concerns our plastics sector, raises significant question marks for our sector.
The plastics sector, besides being one of the most important components of the chemical industry, has a strategic structure that provides intermediate inputs to almost all manufacturing industry sectors in our country. In our sector, where a significant portion of the raw materials used in production is supplied through imports, there is a complex supply chain involving numerous domestic and foreign manufacturers and suppliers. Therefore, it is necessary to consider that the obligations brought under KKDİK directly affect not only chemical substance manufacturers, but also manufacturers and importers using these substances.
THE PROCESS IS MORE CHALLENGING FOR SMES
As PAGDER, in our evaluations based on the feedback we receive from our sector, we see that completing all obligations completely within the current registration calendar entails significant difficulties. Especially the unpredictability of foreign manufacturers' approaches to registration processes within the scope of KKDİK, problems experienced in accessing necessary technical and compositional data, and the costs brought by Only Representative and consultancy services make the process even more difficult for our companies. However, we need to draw attention to the picture that emerges here, especially for our SMEs. The KKDİK registration process is a very comprehensive process requiring technical knowledge, regulatory mastery, data management, and financial resources. While a significant portion of our large-scale enterprises continue their preparations, we observe that the process cannot be carried out at the desired level, especially in our SMEs, due to a lack of expert personnel and technical capacity.
Undoubtedly, as a sector, we support the goals aimed at protecting human health and the environment. However, for a regulation to be successful, it is not enough for its goals to be correct alone. At the same time, the implementation mechanisms ensuring the achievement of these goals must be compatible with the realities of the industry. Otherwise, disruptions that may occur in registration processes, especially in sectors with high import dependence, may lead to interruptions in the supply chain, additional costs, and ultimately production losses.
A TRANSITIONAL PROCESS PROTECTING PRODUCTION IS NECESSARY
At this point, we think it would be appropriate to re-evaluate the implementation calendar by taking into account the sector's current preparedness level and feedback from the field. Our aim is not to delay the implementation of the legislation or eliminate obligations; rather, it is to contribute to the creation of a feasible transition process that will prevent interruptions in production and the supply chain, without compromising the environmental and health gains targeted by the regulation. Especially in the upcoming period, in an environment where our industry struggles with problems such as high financing costs, weak demand, and increasing global competition, it is of critical importance to minimize additional costs and uncertainties as much as possible.
As PAGDER, as in the past, we will continue to share the problems facing our sector with the relevant public institutions based on the information we receive from the field and to develop solution proposals. In the KKDİK process, our priority will be to contribute to establishing a healthy balance between regulations protecting human health and the environment and practices protecting our country's production capacity and competitive power.
This content has been translated using artificial intelligence technology.