SDS (Safety Data Sheet): Impact of KKDIK-Compliant, Turkish and CEA-Signed on Business Continuity

In Turkey, SDS (Safety Data Sheet/GBF) for hazardous substances and mixtures placed on the market is not only a legal requirement; it is also a fundamental document for occupational safety, supply chain continuity and customer trust. Under KKDIK, SDS must be in Turkish and signed by a Chemical Evaluation Expert (CEA). In practice, when these two conditions are not met, it is common to face consequences such as non-compliance findings in inspections, elimination from tenders, or even suspension of shipments.

Structural Power of SDS: KKDIK Annex-2 Standardization

The power of SDS comes from its standardized content structure under KKDIK Annex-2. This structure consists of 16 sections including substance/mixture identification, hazard identification, composition, first aid, firefighting, accidental release, handling and storage, exposure controls and personal protection, physical-chemical properties, stability-reactivity, toxicology-ecology, disposal, ADR/IMDG/IATA transport, regulations and revision notes. The reliability of the form depends not only on the presence of these headings, but also on each being filled with accurate and current data in the Turkish context. For example, full consistency is required between UFI, H/P statements and pictograms on the label and section 2 of the SDS; section 8's occupational exposure limits and PPE selection form the backbone of OSH practices.

Translation or Localization? KKDIK's Expectation

Some companies still refer to SDS as "MSDS" today; however, the valid term in the regulatory world is SDS/GBF. The approach of "translating the existing EU SDS into Turkish and sharing it" is not considered sufficient; because translation is not the same as localization. KKDIK's expectation is a Turkish form where CLP/SEA classification is correctly reflected, national emergency contact information and Turkey-specific references are included, and compliance with UFI and label can be proven when necessary. Therefore, even a good SDS prepared in the EU is not considered "valid" in Turkey without CEA review and signature. The CEA signature serves as a corporate guarantee in terms of classification accuracy, exposure and risk management, and traceability of test and standard references. Moreover, with the use of e-signature, verification and archiving processes are accelerated; in inspections, who published the form, when and with which version is clearly demonstrated.

Field Impact: Storage, Logistics and Recall

SDS being Turkish, CEA-signed and Annex-2 compliant is not just a requirement on paper; it directly affects field safety, warehouse-logistics practices and recall risk. Every piece of information from storage conditions to transport classes has cascading consequences. Incorrect or incomplete transport classification (e.g., ADR), incorrect labeling or outdated H/P statements lead, at best, to loss of customer trust, and at worst, to accidents or legal sanctions. In many companies, the problem is closing the issue by saying "SDS exists"; however, revision discipline is vital in the face of changing classification rules and portfolio dynamics. When a new raw material, supplier change, formula revision or ATP updates come, the SDS must also be updated; otherwise, label, instructions and workplace procedures conflict with the document.

Who Needs SDS?

As for who needs SDS: for manufacturers, importers and distributors, the table is clear; if a substance or mixture classified as hazardous is placed on the market, it is not possible to proceed without SDS. In B2B sales, this has almost become a reflex; in the B2C side, incorrect safety communication is frequently seen in mixture products such as aerosol room fragrances. In this segment, one should not fall into the misconception that "the product goes to the consumer, SDS is not required"; label-SDS consistency and supply chain access to the document must be guaranteed. There is also a platform dimension: the visibility of safety warnings in e-commerce and marketplaces and the transparent presentation of manufacturer/importer information is not only regulatory compliance, but also a matter of brand reputation.

Distinguishing Elements of Quality SDS

Data integrity is at the forefront of elements that distinguish a quality SDS. Classification justifications, test reports and standard references should produce the same message in different sections of the form. There is a silent architectural connection between the PPE recommended in section 8 and the hazard statements in section 2, the handling recommendation in section 7 and the transport classification in section 14. This architecture is easily tested in inspections with a few questions. Questions such as "What scenario did you base your exposure control on?", "Does the warning word on the label match the warning word in SDS section 2?", "Is the UN number you declared in transport the same as the information in the form?" reveal the document's alignment with real life.

Common Mistakes

Common mistakes therefore follow similar patterns: only translation without adaptation to Annex-2; absence of CEA signature; CLP/SEA classification based on old ATP references; ADR/IMDG/IATA tables not being current; revision date and distribution records not being kept. These mistakes often arise from the "We'll complete the documents later" approach under production or sales pressure; however, from the perspective of regulations, safety and supply chain management, the correct order is the opposite: correct information first, then sales.

Conclusion

In conclusion, a Turkish, KKDIK Annex-2 compliant and CEA-signed SDS is not just saying "documents complete". This document is the supporting column in the triangle of the company's risk management, legal compliance and customer trust. When properly structured, it ensures consistency at all touchpoints from OSH to logistics, from labeling to customer communication; it means quick response in inspections, safe operations in the field and sustainable growth in the market. That is why SDS is much more than a form: it is the written expression of the company's safety and compliance culture.

Pier Compliance — Product Safety & EU Compliance

info@piercompliance.com

www.piercompliance.com

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Revision Date: November 19, 2025