KKDİK · TROnly RepresentativeFinal phase
Keeping your chemicals in the Turkish market after 30 September 2026.
KKDİK is Turkey's REACH-equivalent chemical registration regulation. By 30 September 2026 every substance placed on the Turkish market has to hold a registration number — full or provisional. If you manufacture outside Turkey you cannot register in your own name; you appoint an Only Representative established in Turkey. That is what we do.
Free initial assessment · reply within the same working day
Quick check
Does this apply to you?
If you answer "yes" to even one of these, KKDİK affects your Turkish business.
You manufacture outside Turkey and your product is imported into Turkey
A company not established in Turkey cannot file a KKDİK registration in its own name. Either every Turkish importer registers separately, or you appoint one Only Representative established in Turkey who registers on your behalf.
You ship 1 tonne or more of a substance per year
The threshold is 1 tonne per year, per substance, per registrant — not per shipment and not per product. For mixtures the calculation is made on each substance in the formulation, not on the mixture as a whole.
Several Turkish importers buy the same product from you
Without an Only Representative each of them has to register the same substance separately — duplicated cost, and your formulation disclosed to every one of them. One appointment replaces all of it and turns your importers into downstream users.
You have a pre-registration but no dossier submitted
Pre-registration (pre-MBDF) is not registration. It only places you in the information exchange forum for that substance. Until a dossier is submitted through the Chemical Registration System (KKS), the obligation is not fulfilled.
In short: a pre-registration is not enough. By 30 September 2026 a registration dossier — full or provisional — has to be submitted through KKS for every substance you place on the Turkish market.
Consequences
What happens if the date passes?
Without exaggeration, as it stands: KKDİK is built on the same principle as REACH — no data, no market.
- 01 The registration obligation counts as unfulfilled A company that has not completed its provisional registration by 30 September 2026 is not regarded as having met its KKDİK registration obligation.
- 02 The substance cannot be placed on the Turkish market Once the registration obligation has fallen due, the substance may not be supplied in Turkey until that obligation is met — KKDİK's founding rule is "no data, no market". This applies to import exactly as it applies to domestic manufacture.
- 03 Shipments can be held at customs Where registration status is queried, customs clearance stalls. Delivery commitments and your customers' production plans are exposed.
- 04 Administrative sanctions under the Environment Law Non-compliance may be subject to administrative fines under Article 20 of Environment Law No. 2872; the amounts are revalued annually.
- 05 Loss of customers and tenders Turkish downstream users now ask their suppliers for a registration number. A supplier who cannot produce one is dropped at contract renewal and excluded from tenders.
Timeline
The KKDİK registration timeline
Provisional registration is a single date. Full registration is phased by tonnage.
| Date | Stage | Who it concerns |
|---|---|---|
| 31.10.2025 | Pre-MBDF submission | All substances already on the market |
| 31.12.2025 | Lead registrant identification | Substances already on the market |
| 31.03.2026 | Lead registrant provisional registration | Lead registrant per substance |
| 30.09.2026 | Provisional registration deadline | All member companies / individual provisional registration |
| 31.12.2026 | Full registration | ≥1,000 t/year · ≥100 t/year H400–H410 · ≥1 t/year CMR Cat. 1A/1B |
| 31.12.2028 | Full registration | ≥100 t/year |
| 31.12.2030 | Full registration | ≥1 t/year |
Source: the KKDİK Regulation (Official Gazette 23.06.2017/30105 repeated; as amended by Official Gazette 23.12.2023/32408) and the Procedures and Principles on the Implementation of the KKDİK Regulation (05.08.2025), Articles 6, 8 and 10. For substances newly placed on the market, pre-registration is made within 30 days of first placing.
Process
Five steps with AEK Chem
From your substance inventory to the KKS submission — one point of contact, one timetable.
STEP 01
Inventory and scope
We list the substances and mixtures you ship to Turkey, match CAS/EC identifiers and calculate annual tonnage per substance to establish who registers what.
STEP 02
Only Representative appointment
You appoint AEK Chem in writing as your Only Representative in Turkey. We notify your importers, who then move to downstream user status.
STEP 03
Data and dossier
Substance identity, classification, tonnage band and identified uses are compiled in Turkish and structured in IUCLID format by a certified Chemical Assessment Specialist (KDU).
STEP 04
Submission through KKS
The dossier is submitted through the Ministry's Chemical Registration System; where an individual provisional registration is filed, the justification is stated explicitly.
STEP 05
Tonnage tracking and full registration
We keep importer and volume records up to date, handle Ministry feedback and map your substances onto the 2026–2030 full registration schedule.
Why AEK Chem
Authorised, and all under one roof
Registration, safety data sheets and the EU side handled by one team instead of three consultants.
- 01 Established in Turkey, authorisation approved We hold the authorisation required to carry out registration procedures, so the process runs directly rather than through an intermediary.
- 02 Only Representative under KKDİK Article 9 We take on the importers' obligations for manufacturers not established in Turkey, and your importers become downstream users.
- 03 Your formulation stays with us You disclose composition once, to your representative — not to every importer. Commercial confidentiality is part of why the mechanism exists.
- 04 Turkish safety data sheets from the same data The registration data feeds your Turkish-language SDS and labels, so classification does not contradict itself across documents.
FAQ
Frequently asked questions
What exporters to Turkey ask us most in this final phase.
What is KKDİK?
KKDİK is the Turkish Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals, published in Official Gazette No. 30105 (repeated) of 23 June 2017. It is Turkey's national equivalent of the EU REACH Regulation and follows the same logic: substances manufactured in or imported into Turkey at 1 tonne per year or more must be registered with the Ministry.
Does my EU REACH registration cover Turkey?
No. REACH and KKDİK are separate legal regimes. A substance registered with ECHA still needs a separate KKDİK registration to be placed on the Turkish market. Your REACH dossier is, however, the best available starting point — much of the substance identity, classification and physicochemical data can be reused.
Can I register directly as a non-Turkish manufacturer?
Not in your own name. The registration obligation sits with parties established in Turkey. You have two options: each of your Turkish importers registers the substances they import, or you appoint an Only Representative established in Turkey under Article 9 of KKDİK to take on those obligations for you.
What exactly ends on 30 September 2026?
This is the deadline for provisional registration dossiers — for member companies and for companies filing individually. A company that has not completed it by that date is not regarded as having fulfilled its registration obligation, and the substance may not continue to be placed on the Turkish market.
Is appointing an Only Representative mandatory?
No, it is an option rather than an obligation. If you do not appoint one, the registration obligation falls on every Turkish importer that imports 1 tonne per year or more of the substance. In practice, when you have more than one importer or your formulation is confidential, a single Only Representative is both cheaper and safer.
What happens to my importers if I appoint an Only Representative?
They become downstream users and no longer carry their own registration obligation for the substances covered by the appointment. This should be confirmed to them in writing: the name of the representative, the substances covered and their listing as downstream users.
I export mixtures. How is the tonne threshold calculated?
On each substance in the mixture, per year — not on the total weight of the mixture. That is why the first step is always a composition-based inventory. A mixture shipped in modest volumes can still push a single component over the threshold.
Who can prepare the dossier, and in which language?
Dossiers and safety data sheets under KKDİK must be prepared by a certified Chemical Assessment Specialist (KDU) and submitted in Turkish. This is one of the practical reasons non-Turkish manufacturers work with a local representative rather than filing from abroad.
Is a Chemical Safety Report required for every substance?
No. A chemical safety assessment and report mainly comes into play at 10 tonnes per year and above for substances subject to registration. Lower tonnage bands require less. Which band demands which data is settled during the inventory stage.
If I start today, can I still make 30 September?
It depends on the number of substances and the state of your data. We can map your inventory and your current KKS status within a few days, and for narrow portfolios the remaining time is usually sufficient. What matters is not delaying the initial assessment. Write to us and we will reply within the same working day.
Last step
Let's use the remaining — days properly.
Send us your substance list and your Turkish import volumes. We will come back in writing, free of charge: whether you are in scope, which dossier is needed for which substance, and whether it can be done before 30 September.
Contact
Talk to us directly
A short introductory call settles the scope question for most companies in one go.