Our service for the implementation of KKDIK (the Turkish version of REACH), Only Representative and consulting
Update on KKDIK Implementation – What You Need to Know
On 12 August 2025, Turkey’s Ministry of Environment, Urbanization and Climate Change published the finalized Procedures and Principles for implementing the KKDIK (the Turkish version of REACH). These new rules set clear deadlines and steps for companies dealing with chemicals in Türkiye, in order to ensure alignment with EU-style chemical safety, protect human health and the environment, and support sustainable industrial practices.
Key Actions & Deadlines
| What | By When | Who & What Must Be Done |
|---|---|---|
| Pre-Registration (Pre-MBDF) | 31 October 2025 for all substances already on the Turkish market. For substances placed on the market after that date: within 30 days of market entry. | All manufacturers/importers (and their representatives) must submit pre-MBDF via the Chemical Registration System (KKS). This identifies potential registrants and enables joint registration planning. |
| Lead Registrant (LR) Selection | By 31 December 2025 for existing substances; within 6 months after market entry for new substances. | An LR must be chosen to lead the joint dossier. The candidate must notify all members (via KKS) and receive approval from an absolute majority within 30 days. If no candidate agrees, then the Ministry (with TOBB involvement) will appoint one. |
| Provisional / Transitional Registration | Lead provisional dossier by 31 March 2026; member company submissions by 30 September 2026 if full joint registries can’t be completed in time. | This “fallback” route allows continued market access under defined datasets (as per Annex 1) while full registration is in progress. |
| Data Sharing & Joint Submission Requirements | As part of LR’s responsibilities following LR appointment. | The LR must organize data gap assessments, tonnage band definitions, and propose a data-sharing model. These plans must be approved by an absolute majority of the MBDF members; otherwise, LR can be replaced. |
| Extensions / Missing Data | Up to 2 years extension beyond the relevant deadline may be granted. | If registrants cannot complete required data due to technical or sharing issues, the LR may request extension from the Ministry. If data still remains missing after extension, the Chemicals Advisory Group reviews the justification, and the Ministry will make the final call on registration acceptance. |
Supporting Bodies & Governance
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TOBB (Union of Chambers and Commodity Exchanges of Turkey) plays a role in facilitating LR selection when no volunteer arises, helping coordinate joint registration groups, drafting standard agreements, and reporting annually.
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Chemicals Science Group: Composed of academic experts to assist on scientific questions, health/ecotoxicology, etc.
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Chemicals Advisory Group: Coordinated by the Ministry, this body evaluates implementation issues, reviews extension/missing data cases, policies and procedural consistency.
What This Means for Your Business
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If you manufacture or import chemicals into Türkiye (or use them in mixtures or articles with intended release), you must check whether your substances are already pre-registered or whether you need to act immediately to meet the 31 October 2025 deadline.
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Determine whether you (or your company) will act as Lead Registrant, or be a member of a joint submission group. Being LR involves greater responsibilities (data sharing, planning, coordination).
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If full data for a substance cannot be compiled by the deadline, use the provisional registration option—ensure you know what data are required under Annex 1 and what deadlines will apply.
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Ensure your Safety Data Sheets (SDS) are compliant: Turkish language, proper content, uploaded via the Ministry’s system, with certified experts (KDU) involved where required.
Final Registration Deadlines by Tonnage / Hazard Category
| Deadline | Substances in scope |
|---|---|
| 31 December 2026 |
• Substances ≥ 1 000 t/a • Substances ≥ 100 t/a and classified as Aquatic Acute 1 or Aquatic Chronic 1 (H400, H410) • Substances ≥ 1 t/a and classified as CMR Category 1A or 1B |
| 31 December 2028 | Substances in the 100-1 000 t/a band |
| 31 December 2030 | Substances in the 1-100 t/a band |
You can trust our experience in REACH matters and the advantages of having us as your only representative as a Turkey-REACH expert are obvious:
- Authorised representative experienced with chemicals legislation in Turkey
- You do not need a branch office in Turkey
- You are Turkey REACH/ KKDIK-compliant
- Your confidential information only reaches us - your OR
- Your customers do not receive any confidential data
- You have direct influence on the registration process of your substances
- Your Turkish customers do not have to register your substances themselves
- Professional service for all aspects of REACH
Use our Turkey REACH/ KKDIK only representative / authorised representative service so that you can continue to supply your customers with substances and mixtures in Turkey. Please contact us for an offer. We look forward to working with you.