Turkey’s ambitious REACH-style chemicals law—KKDİK (Kayıt, Değerlendirme, İzni ve Kısıtlaması), commonly referred to as Turkey REACH—reached a defining milestone in August 2025. After nearly eight years of progressive deadlines, transitional allowances, and incremental guidance documents, the Ministry of Environment, Urbanization and Climate Change (MoEUCC) has formally issued the long-awaited “Procedures and Principles” (Usul ve Esaslar). These serve as the operational backbone of the regulation, setting out in practical detail how companies must register, evaluate, and communicate about substances placed on the Turkish market.
This development goes beyond a legal formality—it finally closes the long-standing gap between the high-level text of the KKDİK regulation and the mechanics of compliance. Until now, many actors in the supply chain had struggled with uncertainty around issues such as:
i. How joint submissions will be organized and led (including clarity on data-sharing responsibilities and cost allocation).
ii. What role Only Representatives (ORs) can and must play on behalf of non-Turkish manufacturers.
iii. How registrations will be prioritized, sequenced, and accepted by the MoEUCC.
iv. How evaluation and potential restrictions or authorizations will be triggered in practice.
For manufacturers, importers, distributors, and ORs who serve the Turkish market, this publication is the clearest signal to date that the transition period is over. It is now imperative to mobilize compliance teams, allocate resources, and consolidate data into robust dossiers that can withstand regulatory scrutiny.
Leadership roles in joint registration consortia must be clearly established, and companies that delay risk losing influence over critical decisions such as testing strategies, cost-sharing mechanisms, and substance identity determinations.
What this means for different actors in the supply chain
Manufacturers and importers:
You carry the principal registration burden. If you’re outside Turkey, ensure your Only Representative is empowered and resourced, with Turkish language capability and KDU ties. Lock in LR choices now, and budget for data access/testing.
Formulators and distributors:
Don’t assume you’re out of scope. The August 2025 communications emphasize that all actors placing substances on the market must ensure compliance. Even if you’re not the LR, your pre-registration and membership responsibilities still apply.
Downstream users (DU):
Ensure use mapping is captured and communicated up the chain, so exposure scenarios are accurate. Misalignment here creates churn in SDS and dossier updates.
Only Representatives (ORs):
a. Your clients will expect project management discipline—portfolio overviews, status dashboards, LR governance, budget forecasts for LoAs/testing, and clear Annex 1 plans per substance.
b. In essence, the August 2025 milestone transforms KKDİK from a policy framework into a fully functioning chemicals control system. It brings Turkey’s regulatory expectations much closer in line with the EU’s REACH regime, while also introducing local particularities that companies must carefully navigate.
Latest Update:
On 12 August 2025, MoEUCC published the final “Procedures and Principles Regarding the Implementation of KKDİK.” This publication fills the practical gaps that remained after the earlier extensions and announcements.
The new document establishes:
i. A (re)opened pre-registration step with a clear deadline of 31 October 2025 for substances already on the market (with a rolling 30-day window for new substances placed on the market afterward).
Lead Registrant (LR) designation timelines, including a hard date of 31 December 2025 for existing on-market substances and a “within six months” rule for new substances.
ii. A provisional (temporary) registration pathway for cases where the LR can’t pull together a full joint dossier in time—LR by 31 March 2026 and member dossiers by 30 September 2026—using a defined Annex 1 dataset.
iii. Modernized SDS (Safety Data Sheet) obligations, including mandatory upload to the Ministry’s digital system and identification of the certified Chemical Assessment Expert (KDU) in the SDS.
iv. The creation or formalization of advisory bodies (e.g., Chemicals Advisory Group, Chemicals Science Group) to support implementation details and technical consistency.
These measures introduce a staged—and more realistic—on-ramp to full registration, while keeping momentum toward the existing KKDİK registration deadlines in 2026, 2028, and 2030 (depending on tonnage band and hazard profile).
The new timeline briefly (what to do? and by when to do?)
1) Pre-registration (“Pre-MBDF”/Pre-SIEF) – due by 31 October 2025
All potential registrants for substances already on the Turkish market must file pre-registration via the KKS (Chemical Registration System) by 31 October 2025. For new substances placed on the market after that date, you’ll have 30 days from first manufacture/import to pre-register. Pre-registration is essential for joining the joint submission framework and accessing data-sharing discussions.
2) Lead Registrant (LR) selection – by 31 December 2025
For on-market substances, an LR must be designated by 31 December 2025. For new substances, an LR must be appointed within six months of market entry. If industry cannot agree on a volunteer, the Ministry may facilitate selection (with bodies like TOBB, the Union of Chambers and Commodity Exchanges of Turkey, playing a coordinating role). The LR will coordinate joint dossier content, timing, and the path forward if provisional registration is needed.
3) Provisional (temporary) registrations – early/late 2026
If the LR cannot submit a full joint dossier by early 2026, KKDİK now allows a provisional registration with a defined Annex 1 dataset:
a. LR provisional dossier by 31 March 2026
b. Member provisional dossiers by 30 September 2026
This is a safety valve to keep substances legally on the market while final data packages are completed, but it isn’t a “free pass”—it’s a time-bound bridge. Companies that do manage a complete registration before 31 March 2026 don’t need to use the provisional route.
4) Safety Data Sheets (SDS) – upload and expert details
Suppliers must upload SDS to the Ministry’s designated platform. The SDS must include contact details and the certification number/date of a KDU-certified Chemical Assessment Expert—and must otherwise comply with KKDİK’s formatting and content rules (in Turkish). Expect controls around versioning and update triggers.
5) Core KKDİK registration deadlines remain in force
The tonnage/hazard-based full registration deadlines—end of 2026, 2028, and 2030—continue to define when complete dossiers must be in place. The August 2025 Procedures and Principles do not move these horizon dates, but they provide new mechanisms (pre-MBDF, LR selection requirements, and provisional submissions) to keep supply legal while dossiers mature.
Roadmap to KKDİK Compliance for - Q3 2025 to Q4 2026
1) Portfolio triage (now through September 2025)
i. Map every substance you place on the Turkish market to tonnage bands and hazard flags.
ii. Verify pre-registration status (or readiness) in KKS; fix identity inconsistencies now.
iii. If you’re a non-Turkish manufacturer, confirm your Only Representative coverage and mandates.
iv. Identify where you want to be LR vs. where you’d rather be a member (or opt out).
v. Establish communication channels with co-registrants; plan for data access/cost-sharing.
2) Hit the 31 October 2025 pre-registration deadline
i. File all required pre-MBDF entries in time; use the 30-day rolling rule for any new substances after 31 Oct.
ii. Capture use mapping early downstream uses matter for exposure scenarios later.
3) Lock in LR(s) by 31 December 2025
i. For each substance, decide leadership and governance.
ii. If no volunteer emerges, expect Ministry-facilitated solutions (with TOBB involvement).
iii. Document your data gap analysis—which endpoints are covered, which need testing or waivers?
4) Decide: full dossier by March 2026 or go provisional
i. If you can complete the full joint dossier by 31 March 2026 (for higher-priority substances), do it.
ii. Otherwise, have the LR prepare the Annex 1 provisional submission by 31 March 2026, and plan member submissions by 30 September 2026.
iii. Budget for data access (Letters of Access) and test commissioning where needed.
5) Stand up a robust SDS program
Ensure Turkish SDS are KDU-signed and uploaded to the Ministry system.
Align SDS updates with dossier changes, supplier changes, and classification shifts.
6) Prepare for 2026 compliance checks
i. Expect focus on identity sameness across joint registrants, exposure scenario logic, and justification for any provisional filings.
ii. Track Ministry notices and advisory group outputs for clarifications.
Common pitfalls to avoid:
Late Registration: For existing on-market substances, there is no “later” beyond 31 October 2025. Miss this and you jeopardize legal market continuity and your seat at the joint-submission table.
Requirement of Lead Registrant: 31 December 2025 is not a soft date—without an LR, progress stalls on every downstream task (SIEF work, data-sharing, study waivers, Annex 1 prep).
Provisional Registration Provisional registration is a structured contingency with strict content and deadlines (Annex 1, 31 March/30 September 2026). Treat it like a gated project: scope, deliverables, owners, and calendars.
Different Language SDS SDS must be in Turkish, uploaded to the Ministry system, and signed by a KDU-certified expert with credentials shown. Expect increased oversight on SDS quality and alignment with dossier content.
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