Türkiye KKDIK Registration Services - Turkey, Eurasian Economic Union and Other - Chemicals

What is KKDIK?

KKDIK is Türkiye's chemical registration regulation and is broadly equivalent to the EU REACH, thus it is also often called Turkish REACH. It requires manufacturers, importers, and non-Turkish companies placing substances on the Turkish market to register qualifying substances and maintain compliance with chemical safety obligations. KKDIK was published on June 23, 2017, by the Ministry of Environment and Urbanization of the Turkish Republic and formally came into effect on December 23, 2017, with phased deadlines for registration based on tonnage bands.

In March 2026, the Ministry of Environment, Urbanisation and Climate Change announced that all substances must obtain either a temporary registration number or a full registration number by September 30, 2026, to maintain market access in Türkiye.

Supervision Administration

Ministry of Environment, Urbanisation and Climate Change, MoEUCC

Scope of Registration

Substances manufactured in or imported into Türkiye in quantities of one ton or more per year;
Substances in mixtures manufactured in or imported into Türkiye in quantities of one tonne or more per year;
Substances in articles manufactured in or imported into Türkiye that are intended to be released under normal or reasonably foreseeable conditions of use, and the quantity totals one ton per year or more.

Who Shall Register

Manufacturers and importers of substances (including substances in mixtures) in Türkiye;
Manufacturers and importers of articles (intended release) in Türkiye;
Non-Turkish manufacturers of substances, mixtures, and articles must perform the registration obligations under KKDIK via an only representative (OR) based in Türkiye.

Implementation of KKDIK

Key Dates and Important Regulatory Updates

KKDIK was published on June 23, 2017, by the Ministry of Environment and Urbanization of the Turkish Republic and formally came into effect on December 23, 2017. According to the requirements of KKDIK, all chemical substances with an annual production or import volume of 1 ton or above within the territory of Türkiye must complete KKDIK registration with the MoEUCC, or they are prohibited from production, import, or sales in the Turkish market.
On December 23, 2023, Türkiye officially announced to extend the KKDIK registration deadlines to 2026, 2028, and 2030, depending on the tonnage band and hazard classification, namely:

(1) Substances meeting the following conditions should be registered before December 31, 2026:

- Substances manufactured or imported in their own or in a mixture or in goods in an annual amount of 1000 tonnes or more,
- Substances manufactured or imported in their own form or in a mixture or in goods in an annual amount of 100 tonnes or more, and that are within the Aquatic Acute 1 and Aquatic Chronic 1 (H400, H410) hazard categories according to the Regulation on the Classification, Labelling, and Packaging of Substances and Mixtures,
- Substances manufactured or imported in their own form or in a mixture or in goods in an annual amount of 1 tonne or more, and that are within the Carcinogenic, Mutagenic, and Reprotoxic Category 1A and 1B hazard categories according to the Regulation on the Classification, Labelling, and Packaging of Substances and Mixtures.

(2) For substances manufactured or imported in their own form or in a mixture or in goods in an annual amount of 100 tonnes or more, the deadline for registration is December 31, 2028;

(3) For substances manufactured or imported in their own form or in a mixture or in goods in an annual amount of 1 tonne or more, the deadline for registration is December 31, 2030.

In March 2026, the Ministry of Environment, Urbanisation and Climate Change (MoEUCC) issued an announcement regarding the KKDIK chemical registration process, introducing significant updates to the procedures, deadlines, and application requirements for individual temporary registrations. The announcement clearly stipulates that all substances under KKDIK must complete registration—whether temporary or full—by September 30, 2026, to obtain a registration number, regardless of whether a lead registrant (LR) exists or the tonnage level involved. After September 30, 2026, pre-registration numbers will become invalid, and only registration numbers will be recognized. Substances that fail to obtain a valid registration number will not be permitted to enter the Turkish market.

Registration Procedure

The KKDIK registration involves three key stages: pre-registration, temporary registration, and full registration.

Pre-registration

Temporary Registration

Full Registration

Deadline

Pre-registration can still be submitted before September 30, 2026.

September 30, 2026

December 31, 2026 (>=1000 tpa)

December 31, 2026 (100-100 tpa)

December 31, 2030 (1-100 tpa)

Registration Procedure and Data Requirements

1. Substance information (such as substance name, CAS No., EC No., and substance structure);

2. Enterprise information: Indicate the identity of the enterprise (such as Only Representative, importer, manufacturer).

1. Verify LR registration status.

2. Choose registration route: Joint (temporary) registration or individual temporary registration.

3. Prepare registration materials: Prepare IUCLID dossiers, past three years' tonnage data, importer details, etc.

1. Confirm registration tonnage and deadline.

2. Gather required data (physicochemical, ecotoxicological, and toxicological) matching the tonnage band (see table below).

3. Prepare the full dossier.

Full Registration Data Requirements

Registration type	Tonnage band	Data requirements
On-site isolated intermediates under strictly controlled conditions	>= one tonne per year (1t/y)	Existing data only
Transported isolated intermediates under strictly controlled conditions	>=1t/y	Existing data only
	>=1000t/y	KKDIK Annex VII
Registration of regular substances	>=1t/y	A) 1-10t/y standard registration, all data specified in Annex VII; B) 1-10t/y, The information on physicochemical properties specified in Annex VII, for substances that do not meet either of the criteria specified in Annex 3;
	>=10Tt/y	KKDIK Annex VII+VIII
	>=100t/y	KKDIK Annex VII+VIII+IX
	>=1000t/y	KKDIK Annex VII+VIII+IX+X
	Note: for >=10t/y regular registration, a chemical safety report (CSR) is also needed.

1. Intermediates can be divided into three categories: Non-isolated intermediates, on-site isolated intermediates, and transported isolated intermediates.

Non-isolated intermediates: an intermediate that during synthesis is not intentionally removed (except for sampling) from the equipment in which the synthesis takes place.

On-site isolated intermediate: an intermediate not meeting the criteria of a non-isolated intermediate and where the manufacture of the intermediate and the synthesis of (an)other substance(s) from that intermediate take place on the same site, operated by one or more legal entities;

Transported isolated intermediates: an intermediate not meeting the criteria of a non-isolated intermediate and transported between or supplied to other sites;

2. The data requirements under Annexes VII, VIII, IX, and X of KKDIK are consistent with those of EU REACH. However, compared to EU REACH, KKDIK introduces the concept of a Chemical Assessment Expert for data review during full registration. When submitting data to the authority, it must be indicated that the relevant data has been reviewed by a Chemical Assessment Expert, a requirement not present in EU REACH.

Post-Registration Obligations

Upon successful registration, companies must promptly update the product’s Safety Data Sheet (SDS) with the new registration number. Furthermore, the dossier must be actively updated in case of changes to tonnage bands, uses, import structures, or other relevant corporate and technical data.

Comparison Between KKDIK and EU REACH Regulations

In terms of data review, KKDIK is stricter than EU REACH. KKDIK introduces the concept of a Chemical Assessment Expert, requiring that registration dossiers under KKDIK be prepared by a Chemical Assessment Expert and uploaded to the KKS system. Pre-registration does not require a Chemical Assessment Expert.
Under KKDIK, dossiers are prepared using the KKS system, whereas under EU REACH, dossiers are prepared using IUCLID files.
KKDIK does not distinguish between phase-in substances (existing substances) and non-phase-in substances (new substances).

KKDIK Compliance: Frequently Asked Questions for Industry

Q1: What is "Individual Temporary Registration"?

A1: In cases where a complete registration dossier cannot be submitted immediately, companies may opt for the Individual Temporary Registration pathway. This allows a registrant to secure a registration number independently and in advance, ensuring uninterrupted trade and regulatory compliance in Türkiye.

Q2: Will pre-registration numbers become invalid after September 30, 2026? Will only full or temporary registrations be recognized?

A2: Yes. To maintain market access in Türkiye, all companies must secure a valid registration number – either temporary or full – by September 30, 2026. This deadline applies across all tonnage bands. Therefore:

Only official registration numbers (temporary or full) are granted market access.
Pre-registration numbers will become invalid and will no longer hold regulatory compliance value.

Q3: What are the data requirements and estimated timelines for Individual Temporary Registration?

A3: Data requirements are minimal; companies can utilize their existing data. The estimated timeline is 1 to 2 months.

Q4: What are the differences between Turkish KKDIK and EU REACH?

A4: Compared to EU REACH, KKDIK introduces the concept of a Chemical Assessment Expert for data review during full registration. When submitting data to the authority, it must be indicated that the relevant data has been reviewed by a Chemical Assessment Expert, a requirement not present in EU REACH.

Q5: What are the post-registration obligations once a KKDIK registration is completed?

A5: Upon successful registration, companies must promptly update the product’s Safety Data Sheet (SDS) with the new registration number. Furthermore, the dossier must be actively updated in case of changes to tonnage bands, uses, import structures, or other relevant corporate and technical data.

Q6: One company has completed the pre-registration under the assistance of OR1. Is it available for the company to switch from its original Only Representative (OR1) to a new one (OR2) to execute Individual Temporary Registration? What is the procedure?

A6: Yes, transferring Only Representatives is fully permitted under KKDIK. To transition to OR2 for Individual Temporary Registration, companies can choose one of three approaches based on their circumstances:

Option 1: Submit a formal tri-party transfer agreement (signed by the company, OR1, and OR2) alongside the new Power of Attorney (POA) to the Turkish Ministry of Environment, Urbanization and Climate Change. Timeline: 5 to 10 working days. This approach is ideal for companies with numerous substances, as the authorities can process the transfers in bulk. Once approved, OR2 can initiate the temporary registration.

Option 2: Following a mutual termination agreement, OR1 manually deactivates or deletes the existing pre-registration within the KKS system. Concurrently, the company executes a new POA with OR2, allowing the new representative to resubmit the pre-registration and immediately proceed with the temporary registration.

Option 3: If OR1 is uncooperative or refuses to sign a transfer agreement, the enterprise may issue a unilateral termination notice to legally sever the relationship. OR2 will archive this document for compliance audits, execute a new POA, resubmit the pre-registration, and finalize the temporary registration.

Q7: Under what conditions is a company eligible to submit an Individual Temporary Registration?

A7: An Individual Temporary Registration can be pursued if any of the following scenarios apply:

The Lead Registrant (LR) has not yet completed the joint submission dossier.
The LR has registered, but the Letter of Access (LoA) data fees have not yet been published.
No Lead Registrant has been elected or designated for the substance.
The LR has published the LoA cost, but the enterprise opts out of the joint submission due to unreasonable pricing, the protection of proprietary business secrets, or other commercial strategies.

Q8: If a substance lacks a harmonized classification under EU REACH but carries self-classifications of H400 and H410, how is the KKDIK registration deadline calculated?

A8: KKDIK closely mirrors EU REACH classification principles when determining deadlines, using the following hierarchy of precedence:

Harmonized Classification: Takes absolute precedence if available.
Self-Classification: If no harmonized classification exists, the self-classification established by the EU REACH Lead Registrant is utilized.

Because the substance carries H400 and H410 classifications, these environmental hazards must be accounted for. If the pre-registered volume falls within the 100–1,000 t/a band, the final deadline for compliance is December 31, 2026.

Q9: What documentation is mandatory to complete a KKDIK Individual Temporary Registration?

A9: The current KKS system requires the submission of the following data and documentation:

Substance identification and basic properties
A valid Power of Attorney (POA) (required for non-Turkish manufacturers appointing an OR)
Local Turkish importer information
Average tonnage volumes spanning the preceding three years
Identified uses and exposure scenarios
A compliant Safety Data Sheet (SDS)
The original pre-registration number

⚠️ Note on Analytical Data: Analytical spectra and physicochemical testing data can be temporarily exempted during this temporary registration stage. However, full spectral and analytical data must be integrated into the dossier later during the transition to the full registration.

Q10: What happens if a company fails to obtain a KKDIK temporary registration number by September 30, 2026?

Substances without a valid temporary or full registration number can no longer be legally placed on the Turkish market after September 30, 2026.

Our Services

KKDIK Regulatory Compliance Consulting and Training;
KKDIK OR Service;
KKDIK Pre-registration;
KKDIK Registration (Full & Interim)
Türkiye CLP Regulation Regulatory Compliance Consulting and Training;
Türkiye CLP Regulation OR Service;
C&L Notification under Türkiye CLP Regulation;
Turkish SDS and Labeling Preparation;

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

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