Turkish REACH: KKDIK Registration

The new Turkish REACH Regulation (KKDIK) requires companies to pre-register and register substances that are manufactured, or placed on the Turkish market, either on their own or in mixtures, or in articles with an intended release, which are manufactured or imported in Turkey in quantities equal to, or above, 1 metric tonne per annum. 

Non-Turkish manufacturers and formulators exporting chemicals to Türkiye can appoint an Only Representative (OR) to submit the KKDIK registration and the CLP notification on behalf of their Turkish importers. 

On Saturday 23rd of December 2023, the Turkish Ministry of Environment, Urbanization and Climate Change officially published a KKDIK regulation amendment, including the details on registration deadline extensions. The registration deadline has been extended according to tonnage bands and hazard categories, for a total of seven years, as follows:

• 3 years extension (until 31 December 2026):
  • for the substances manufactured/imported at >1000 tonnes per annum (tpa);
  • for the substances manufactured/imported at 100-1000 tpa which are classified as Aquatic Acute 1 and Aquatic chronic 1; and
  • for the substances manufactured/imported at >1 tpa which are classified as CMR Category 1A/1B
• 5 years extension (until 31 December 2028):
  • for the substances manufactured/imported between 100-1000 tpa
• 7 years extension (until 31 December 2030):
  • for the substances manufactured/imported between 1-100 tpa

After the appropriate deadlines, substances, either on their own in mixtures or in articles, that are equal to, or above, 1 metric tonne per annum, cannot be manufactured or placed on the market if they are not registered in accordance with the relevant provisions of KKDIK.

Principle and Procedures Guideline

In August 2025, the Principles and Procedures Guideline was published by the Turkish Ministry of Environment, Urbanization and Climate Change. While the existing registration deadlines have been confirmed, the guideline introduces a new registration step referred to as “provisional registration.”

Provisional registration is not applicable to lead registrant companies that complete and submit their full registration dossiers by 31 March 2026. If a lead registrant company submits a full registration dossier by 31 March 2026, member registrants are required to submit their member registration dossiers in accordance with the deadlines outlined above.

If the selected KKDIK lead registrant is unable to fulfill its obligations for full registration, a provisional registration dossier must be submitted to the Ministry of Environment, Urbanization and Climate Change (MoEUCC) by 31 March 2026, including the data specified in Annex 1 of the Guideline.

In cases where a lead registrant submits a provisional registration dossier by 31 March 2026, member registrants must submit their provisional registration dossiers by 30 September 2026.

Individual Provisional Registrations

The Turkish Ministry of Environment, Urbanization and Climate Change has announced an important update regarding the KKDIK registration process through two official communications dated March 4,2026 and March 6, 2026.

Due to delays experienced in the Lead Registrant appointment process, companies are now encouraged to submit “Individual Provisional Registrations” to prevent disruptions in the registration process.​

Key Points​

• Companies may now submit individual provisional registrations even if a LR has already submitted their full dossier if they attach a reasonable justification (es: LoA costs being high, differences in opinion within the SIEF, no declaration of lead registrant) 
• Companies that complete their provisional registrations by September 30, 2026, will be able to continue supplying their substances to the Turkish market without interruption regardless of tonnage and classification.​
• If some of the information required for the individual registration cannot be provided by September 30,2026, companies may submit temporary registration files by justifying the reason for the missing information.

What do you need for an individual provisional registration is the same as the information requirements of Annex-I of Principles and Procedures.

There are some advantages of proceeding with individual provisional registration by 30^th of September which are:

• No need to wait for a Lead registrant declaration
• No need to sign SIEF agreement
• No need to buy Letter of Access
• Reduced amount of information required

Turkish Chemical Regulation Services

Intertek global experts can assist you step-by-step with complying with the Turkish REACH (KKDIK) Regulation.  Our regulatory services include:

• KKDIK Turkish Only Representative: Intertek can act as a Turkish Only Representative as prescribed by KKDIK, Article 9, through our Intertek Türkiye legal entity
• KKDIK Pre-Registration: Intertek can submit substance pre-registrations on your behalf through the KKS system
• Classification & Labelling Notification: Intertek can prepare and submit the notification of classification and labelling to the competent Turkish Authority in order to form the C&L inventory
• KKDIK Registration: Intertek can prepare and submit the full or provisional registration or the member registration on your behalf, and provide support in monitoring/communication of SIEF activities
• Safety Data Sheet: Intertek’s Experts, certified according to the ANNEX XVIII of KKDIK will prepare, check and certify Safety Data Sheets in the Turkish language.