With the publication of the Procedures and Principles Regarding the Implementation of the KKDIK Regulation and the recent updates, several changes have been introduced to the KKDIK process. Establishing a clear roadmap has become essential for maintaining compliance.
What are the KKDIK Procedures and Principles and what has changed?
The Procedures and Principles Regarding the Implementation of the KKDIK Regulation were published on 12 August 2025 by the Ministry of Environment, Agriculture and Climate Change of the Republic of Türkiye.
This regulatory document introduced the following changes:
- Pre-registration deadlines were updated.
- A deadline was set for determining the lead registrant.
- A temporary registration process was introduced.
- The Chemicals Science Group and Chemicals Advisory Group were established to support KKDIK process.
- A dedicated software package for Safety Data Sheets was introduced. SDSs must be prepared in accordance with Annex 2 of the KKDIK Regulation and uploaded to the Ministry’s SDS software package.
What are the KKDIK deadlines?
The key deadlines introduced by the Procedures and Principles are as follows:
| Deadline | Requirements |
| 31 October 2025 | Registrants must complete their pre-registrations and become MBDF members. For substances manufactured or imported for the first time after this date, pre-registration must be completed within 30 days following the placing on the market. |
| 31 December 2025 | For substances manufactured or imported before the publication of the Procedures and Principles, the lead registrant must be determined by this date. For substances manufactured or imported afterwards, the lead registrant must be determined within six months. |
| 31 March 2026 | If the registrant cannot fulfil full registration obligations, a temporary registration must be submitted by this date. Companies wishing to submit an individual dossier instead of a joint submission must also submit a temporary registration if they cannot meet full registration requirements. |
| 30 September 2026 | Following the temporary registration by the lead registrant, member registrants must submit their temporary registrations by this date. |
Registrants that complete temporary registration must then follow the KKDIK full registration deadlines below:
| Deadline | Tonnage |
| 31 December 2026 | • Substances manufactured or imported on their own or in a mixtures at ≥1000 t/y |
| • Substances at ≥100 t/y classified as Aquatic Acute 1 or Aquatic Chronic 1 (H400, H410) under the SEA (Turkey CLP) Regulation | |
| • Substances at ≥1 t/y classified as CMR Category 1A or 1B under the SEA Regulation | |
| 31 December 2028 | • Substances manufactured or imported at ≥100 t/y |
| 31 December 2030 | • Substances manufactured or imported at ≥1 t/y |
What are temporary and full registration?
Temporary registration allows companies to begin the KKDIK registration process by submitting physicochemical properties and essential safe use information, even if certain data required for full registration are not yet available. This mechanism prevents interruptions in placing chemicals on the Turkish market and provides additional time to complete missing information.
Full registration, on the other hand, requires the submission of all scientific and technical data available for the substance. Substances that are not fully registered by the relevant deadlines may not be placed on the Turkish market.
Which documents are required in the KKDIK process?
Information required for temporary registration as defined in Annex 1 of the Procedures and Principles:
- Identification (KKS Section 1.1)
1.1 Composition (KKS Section 1.2)
1.2 Analytical Information (KKS Section 1.4)
1.3 Suppliers – An indication as to which of the information submitted has been reviewed by a chemical assessment expert chosen by the manufacturer or importer and keep this information up to date (free of charge) (KKS Section 1.7)
1.4 Joint Submission (KKS Section 1.5)
- Globally Harmonised System (KKS Section 2.1)
- Manufacture, Use and Exposure (KKS Section 3)
3.1 Estimated Quantities (KKS Section 3.2)
3.2 Sites (KKS Section 3.3)
3.3 Information on Mixtures (KKS Section 3.4)
3.4 Use and Exposure Information (KKS Section 3.5)
3.5 Uses Advised Against (KKS Section 3.6) - Physical and Chemical Properties (KKS Section 4)
- Guidance on Safe Use (KKS Section 11)
Information required for full registration according to Article 11 of the KKDIK Regulation:
- Technical dossier
- Identity of the manufacturer(s) or importer(s)
- Identity of the substance
- Information on manufacture and uses
- Classification and labelling
- Guidance on safe use
- Study summaries
- Robust study summaries
- An indication as to which of the information submitted has been reviewed by a chemical assessment expert chosen by the manufacturer or importer
- Testing proposals
- Exposure information (1-10 tonnes)
- A request as to which of the information should not be made available on the Internet
- Chemical Safety Report (10 tonnes or above)
- Legitimate possession of or have permission to refer to the full study report summarised for the purpose of registration
Should you seek consultancy support?
The involvement of a certified Chemical Assessment Expert (CAE) is a legal requirement under KKDIK. The expert’s qualification certificate must be submitted during temporary registration, and other required information must also be entered by a CAE. SDSs must likewise be prepared by a certified expert. For full registration, the expert must confirm that the technical dossier has been reviewed.
Beyond the expert requirement, the KKDIK process involves complex legal and technical stages. Working with a specialised consultancy reduces technical workload, improves data management and minimises legal and administrative risks.
Chemleg provides comprehensive KKDIK consultancy services, including:
- Product stewardship
- TR REACH (KKDIK) Registration
- Only Representation
- KKDIK Authorisation and Restriction
- IUCLID and KKS Dossier Support
- SDS and e-SDS
- Chemical Assessment Expert Training
- Data Sharing Management
KKDIK Checklist
You may download our checklist to plan your process.