Türkiye KKDIK Update: Pre-Registration Closes with over 42000 Dossiers Submitted

The Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) has released an official update on registration progress under KKDIK (Türkiye REACH). Following the September 30, 2026 pre-registration deadline, authorities have received over 42,000 applications.

This milestone marks the end of the initial transitional period that began in 2017. The regulatory focus has now officially shifted from initial filings to dossier evaluation, full registration, and market enforcement.

Key Points of the Official Announcement

1. Over 42,000 Submissions; Pre-registration Phase Concludes

As of September 30, 2026, the authorities have received over 42,000 KKDIK registration applications. Although there were minor technical glitches in the Chemicals Registration System (KKS) during the registration period, overall operations remained stable. After the deadline, the system will remain open to handle "backlog" matters for registrations not yet completed. Starting October 1, 2026, chemicals exported to Turkey must have a valid (pre-)registration number to be placed on the market; pre-inquiry numbers are no longer valid.

2. Transition Rules for Pending Registrations: Use Application Number for Transition

The announcement clarified transitional arrangements: for substances whose registration dossiers have been submitted but for which registration numbers have not yet been issued, companies may temporarily use the application number to maintain compliance until the registration number is granted. The KKS system will remain open to: continue processing registration and notification procedures under KKDIK and the SEA (Classification, Labeling and Packaging) Regulation; continue accepting substance registrations; update existing dossiers (e.g., changes in importers, spectral information, etc.); and complete applications that failed to obtain registration numbers due to technical system issues.

3. Tonnage Updates On Hold

Companies needing to update tonnage information in their submitted pre-registration dossiers are advised not to make changes on their own for the time being. They should wait for a subsequent announcement from the Ministry of Environment, at which point updates can be processed via KKS.

4. Full Registration Extension Application Channel Under Construction

For substances that have obtained pre-registration and whose full registration deadline is December 31, 2026 (i.e., substances with annual tonnage ≥ 1,000 tons, and high-hazard substances), an online application channel for requesting an extension of the registration period is currently being built in KKS. Specific details will be announced separately.

5. Reminder on Administrative Fee Payment

Companies submitting registration applications must pay the official administrative fee within 15 days of submission. Dossier evaluation will only commence after the fee has been paid.

6. Regulatory Enforcement Has Begun

The announcement confirmed that regulatory oversight of chemical manufacturers and importers with registration obligations has officially started. Future updates will be released via the Turkish Ministry of Environment's website and the Chemicals Helpdesk.

Market Outlook: Navigating Turkey's Post-Pre-Registration Era

As a major manufacturing and re-export hub bridging Europe and Asia, Türkiye relies heavily on imported chemicals. KKDIK, published in June 2017, is largely aligned with the EU REACH regulation, with a registration threshold of 1 ton or more per year in production or import volume. Foreign companies must fulfill registration obligations through a sole Only Representative (OR) located in Turkey. Following multiple extensions of the regulation, the concentrated submission of over 42,000 dossiers marks the basic formation of the Turkish National Chemical Inventory, officially ushering the Turkish chemical market into an era of "market access with registration numbers."

For companies, the timeline after September 30 is particularly critical:

• December 31, 2026: Full registration deadline for substances with annual tonnage ≥ 1,000 tons, and high-hazard substances (Aquatic Acute/Chronic Toxicity Category 1 substances with annual tonnage > 100 tons, and CMR 1A/1B substances with annual tonnage > 1 ton).
• December 31, 2028: Full registration deadline for substances with annual tonnage of 100–1,000 tons.
• December 31, 2030: Full registration deadline for substances with annual tonnage of 1–100 tons.

It must be emphasized that pre-registration is merely an "entry ticket." Companies that have obtained a pre-registration number must still complete data supplementation, cost-sharing negotiations, and full dossier submission before the respective deadlines to obtain a full registration number. With the initiation of official regulatory enforcement, goods without valid registration numbers face risks such as customs detention, substantial fines, or even direct loss of market access. Exporting companies are advised to promptly incorporate "Turkish Registration Status Verification" into their annual compliance reviews and simultaneously verify the registration coverage of upstream and downstream supply chains.

Action Plan for Companies

Based on this announcement and the current KKDIK transitional arrangements, the Industrial Chemicals Division of CIRS recommends that companies take action according to their specific situations:

• Companies that have submitted but not yet received a registration number: You may temporarily use the application number to maintain trade, while simultaneously expediting the completion of outstanding matters via the still-open KKS system. Ensure the administrative fee is paid within 15 days of submission to avoid delays in dossier evaluation.
• Companies dealing with high-tonnage/high-hazard substances: December 31, 2026, is the next hard deadline, with less than 3 months remaining. Immediately assess data gaps and the progress of Lead Registrant (LR) data purchasing. If an extension is necessary, closely monitor the opening time of the official extension application channel.
• Companies not yet registered or newly entering the Turkish market: A registration number must be obtained before the first manufacture or import. It is recommended to promptly complete substance inventory and registration pathway assessments to avoid goods being detained upon arrival at the port.

What Can CIRS Do for You

With nearly 20 years of expertise in global chemical compliance, CIRS has collaborated with senior local ORs in Turkey for many years. We have assisted thousands of domestic and international companies in completing over 2,000 KKDIK pre-registrations, possessing extensive practical experience in the entire process from compliance advice, data gap analysis, and Lead Registrant data purchasing to dossier compilation and submission. Regarding the KKDIK regulatory framework, CIRS provides companies with:

• KKDIK Pre-registration (Joint submission / Individual pre-registration)
• KKDIK Full Registration (Lead Registrant registration and joint submission)
• Turkish CLP (SEA Regulation) Notification
• Turkish SDS Compilation and Labeling Compliance
• Turkish OR Services and Post-registration Compliance Maintenance (Tonnage updates, importer information maintenance, handling official inquiries, etc.)

Leveraging our synergistic service capabilities for both EU REACH and Turkish KKDIK regulations, CIRS helps companies achieve multi-country market access in a one-stop manner, significantly reducing compliance costs.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Note: Some of the timelines mentioned in this article may be adjusted by subsequent official announcements. Please refer to the latest releases from the Turkish Ministry of Environment, Urbanization and Climate Change and the Chemicals Helpdesk. Original announcement: Announcement on the Registration Process Under KKDIK (MoEUCC, 2026-10-05).