KKDİK deadline 30 September 2026: what exporters to Turkey must do

KKDİK — the Turkish Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals — is Turkey's national counterpart to the EU REACH Regulation. It was published in Official Gazette No. 30105 (repeated) of 23 June 2017 and has been advancing on a phased timeline ever since. The summer of 2026 is one of its busiest points: 30 September 2026 is the deadline for submitting provisional registration dossiers to the Ministry.

This article explains what each part of the timeline means, whom 30 September binds, and what to do, in sequence, with the time you have left. The aim is not to alarm you but to help you read the date correctly.

1. Where exactly are we in the timeline?

The KKDİK process has three distinct stages, which are frequently confused with one another:

• Pre-registration (pre-MBDF): notifying the substance to the Ministry and joining the information exchange forum with the other companies that will register the same substance. For substances newly placed on the market, pre-registration is made within 30 days of first placing.
• Provisional registration: submitting the essential information about the substance through the Chemical Registration System (KKS) while the full dossier is not yet ready.
• Full registration: submitting the technical dossier containing physicochemical, toxicological and ecotoxicological data, exposure scenarios and, where required, the chemical safety report.

The timeline the Ministry communicated through the chambers of industry set two dates for provisional registration: 31 March 2026 for lead registrants and 30 September 2026 for member companies. The first date has passed. The date now in front of us is the second.

2. What changed? Individual provisional registration

KKDİK follows the same logic as REACH: companies registering the same substance come together, commission expensive tests once and share the cost. In this structure the company that prepares the dossier is the lead registrant; the others contributing to and drawing on the data are member companies.

In practice the model stalled: for many substances no lead registrant emerged, or the lead identification process could not be completed. Following the Chemicals Advisory Group's assessment, and as communicated through the chambers of industry (ICI announcement, 10 March 2026), provisional registration processes may also be carried out individually. Companies can submit their dossiers through KKS, stating the justification for the individual route.

The practical consequence: "there is no lead registrant, so we are waiting" is no longer a valid excuse. It is also good news — the process can now be moved forward on your own.

3. Who does 30 September 2026 bind?

The short answer: anyone who manufactures in, or imports into, Turkey 1 tonne or more of a chemical substance per year. That is far wider than the chemical industry alone. Typical cases in scope:

• Manufacturers importing raw materials, additives, solvents, paints, inks, adhesives or textile chemicals from abroad;
• Companies manufacturing a substance at their own site;
• Companies importing mixtures where a component substance exceeds 1 tonne;
• Only Representatives acting on behalf of manufacturers established outside Turkey.

The quantity is calculated per substance and per year. A textile or metalworking company saying "we don't produce chemicals, we only use them" may well be a registrant if it does the importing itself. What determines the obligation is the activity, not the name of the sector.

What falls outside scope

Some product groups are outside the registration obligation or partly exempt: wastes, radioactive substances, substances under customs supervision in transit, and products with their own legislation such as medicines and cosmetics. But exemptions are usually defined at the level of the "use" rather than the "product"; the same substance may be exempt in one use and subject to registration in another. Any claim of exemption should therefore be justified substance by substance before it is relied on.

4. What happens if it is not done by 30 September?

It is worth avoiding exaggeration here, because there is a great deal of fear-marketing in this field. The honest picture:

• A company that does not complete its provisional registration in time is not regarded as having fulfilled its registration obligation for the period concerned.
• KKDİK's core principle is "no data, no market": a substance for which the obligation has arisen but has not been met cannot lawfully be placed on the market.
• Companies that complete provisional registration may benefit from additional flexibility and time granted by the Ministry to complete full registration. Missing provisional registration means losing that flexibility too.
• Failure to comply with the registration obligation may be subject to administrative sanctions under the Environment Law.

So the real risk is not the fine line but the interruption of your supply chain: a substance without a registration number becomes one your customer can no longer buy from you.

5. The order to follow in the time that remains

1. 01Build the substance inventoryFrom the last 12 months of import and production records, produce a substance-level list: name, CAS and EC number, annual quantity, supplier, intended use.If you import mixtures you need a component-level breakdown — ask your supplier for composition data.
2. 02Establish your roleManufacturer, importer, downstream user, or Only Representative? The obligation depends on this, and choosing the wrong role compromises the dossier from the outset.
3. 03Check pre-registration and MBDF statusHas each substance been pre-registered, and is there a lead registrant in the information exchange forum? If not, take the individual provisional registration route.
4. 04Collect the missing dataClassification and labelling, physicochemical data, use descriptions. The safety data sheets from your supplier are the primary source here.
5. 05Prepare and submit the dossier in KKSAccess to KKS through EÇBS, company and authorisation set-up, substance-level data entry, validation and submission.If authorisation is being set up for the first time it can take days — don't leave it to the final week.
6. 06Plan the full registration scheduleThe work does not end when provisional registration is done. Place your substances into the 2026 / 2028 / 2030 phases and budget for testing and data sharing now.

6. Afterwards: the full registration phases

The amendment published in Official Gazette No. 32408 of 23 December 2023 reset the full registration deadlines. The current phases:

Note the point that catches companies out: the 31.12.2026 phase is only three months after 30 September. For companies with high-tonnage or CMR substances, autumn 2026 will be a period when provisional and full registration preparation overlap. The two need to be run as a single plan, not two separate exercises.

For the whole KKDİK process — scope, pre-registration, MBDF, dossier content, cost items — step by step: How to register under KKDİK.

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.