How to register under KKDİK: a step-by-step guide through KKS

"How do I register under KKDİK?" has no short answer, because registration is not a single form. It is the preparation of a dossier that runs from the identity of the substance to its hazard data. This article sets out the process as it actually is, in sequence. KKDİK — the Turkish counterpart of EU REACH — was published in Official Gazette No. 30105 (repeated) of 23 June 2017 and rests on the same principle: no data, no market.

1. Scope first: are you a registrant?

The registration obligation depends on the answers to three questions:

• What do you do? Do you manufacture the substance in Turkey, or import it? The obligation attaches to these two roles. If you buy domestically and use it, you are a downstream user and not a registrant — though you do have downstream user obligations.
• How much? The threshold is 1 tonne per year, per substance. For mixtures the basis is not the total weight of the mixture but the annual quantity of each substance in it.
• Which substance? Some substances and uses are outside scope or exempt from registration: wastes, radioactive substances, substances under customs supervision in transit, products with their own legislation. Polymers are exempt from registration; but a registration obligation may arise for the monomers that make them up.

2. Pre-registration and the Substance Information Exchange Forum (MBDF)

Pre-registration notifies your substance to the Ministry and places you in the same forum as the other companies that will register it. This forum is the MBDF (Substance Information Exchange Forum) and is the heart of KKDİK's cost logic: it prevents the same tests — and therefore animal studies and expense — being repeated for the same substance.

There are two roles within the forum:

• Lead registrant: the company that prepares and submits the joint technical dossier and coordinates the testing.
• Member company: the company that completes its own registration by acquiring access to the lead registrant's data.

For substances newly placed on the market, pre-registration is made within 30 days of first placing. For existing substances, the lead registrant identification process was tied to 31 December 2025.

3. Provisional registration: 30 September 2026

Where the full dossier is not yet ready, provisional registration comes in. It is the declaration through KKS of the essential information about the substance. Its purpose is to let the Ministry see the market inventory of substances, and to give companies time to prepare full registration.

The information typically required for provisional registration:

Following the Chemicals Advisory Group's assessment, and as communicated through the chambers of industry (ICI announcement, 10 March 2026), provisional registration may also be done individually. For the deadline and details: KKDİK deadline 30 September 2026.

4. What is in the full registration dossier?

Full registration is the heavy part. The technical dossier typically contains:

• Substance identity and analytical information: spectra, chromatograms, purity profile.
• Physicochemical properties: flash point, density, particle size, explosivity, flammability.
• Toxicological data: acute toxicity, skin/eye irritation, sensitisation, mutagenicity, repeated-dose toxicity.
• Ecotoxicological data: aquatic toxicity, biodegradation, bioaccumulation.
• Chemical Safety Report (CSR): mandatory at 10 t/year and above; contains exposure scenarios and risk management measures.

The full registration deadlines were phased by the amendment published in Official Gazette No. 32408 of 23 December 2023: 31.12.2026 (above 1,000 t/year; above 100 t/year H400–H410; above 1 t/year CMR), 31.12.2028 (above 100 t/year), 31.12.2030 (all substances above 1 t/year).

5. Application steps in KKS

1. 01EÇBS accessThe company logs in to the Integrated Environmental Information System. Access begins with the legal representative's e-Government identity.
2. 02Company set-up and authorisationThe Chemical Registration System application is selected; the staff member carrying out the process is authorised on behalf of the company.This is the step where most time is lost at first set-up.
3. 03Creating the substance recordA separate record is opened for each substance; CAS/EC numbers are validated in the system.
4. 04Data entryIdentity, tonnage, classification, use and physicochemical data are entered into the relevant templates.
5. 05Check and submissionAfter system validation the dossier is submitted to the Ministry; an application number is issued and archived.

6. Who can prepare the dossier? (KDU)

The person preparing KKDİK dossiers and safety data sheets must be a Chemical Assessment Specialist (KDU) — someone who has completed the training set out in Annex-18 of the Regulation and passed the examination of an authorised certification body. As of 31 December 2023 the KDU title replaced the former "safety data sheet author". For detail: Is a safety data sheet mandatory in Turkey? Because filings are in Turkish and require a certified KDU, this is one of the practical reasons manufacturers outside Turkey work through a local representative.

7. Where does the cost really come from?

There is no single figure for "how much does KKDİK registration cost", because the cost varies per substance and tonnage band. But the items are known, and knowing them makes budgeting possible:

• Letter of Access (LoA) / data access fee: the right to use the lead registrant's data. In most dossiers this is the largest item, and it rises with the tonnage band.
• Testing cost: where there is a data gap, laboratory studies are needed. Ecotoxicology and repeated-dose studies are the most expensive.
• Consultancy / KDU service: dossier preparation, MBDF negotiations, CSR writing.
• Ministry fees and system charges.

The most effective way to reduce cost is to build the inventory early and narrow the number of substances that are genuinely subject to registration. In practice many companies find, after a scope analysis, that a significant part of their list is exempt or below the threshold.

8. The six most common mistakes

1. Declaring a mixture as a substance (or vice versa).
2. Copying the CAS/EC number from a supplier document without checking it.
3. Calculating tonnage per product rather than per substance.
4. Opening a second registration as importer without knowing the non-Turkish manufacturer has appointed an Only Representative.
5. Believing you are a registrant when you are a downstream user — or the reverse.
6. Leaving the process to the final month: EÇBS authorisation and obtaining composition data from a supplier take days.

Frequently asked questions

This article is for general information; for your company's specific situation the official regulation text and Ministry announcements should be relied on. Last updated: 5 August 2026.