KKDIK enforcement principles finalised: key deadlines and industry guidance released

06 Oct 2025

The Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) has taken a significant step forward in the implementation of Turkey’s REACH-like chemical regulation (KKDIK), with the official adoption of the KKDIK Enforcement Principles and Procedures on August 12, 2025. The announcement, published in the Official Gazette and signed by the Minister, introduces crucial updates including finalized pre-registration, transitional and full registration deadlines.

This marks a pivotal moment for businesses placing chemical substances on the Turkish market, reinforcing the importance of early compliance and strategic registration planning.

Key highlights from the new regulation

Pre-registration deadlines

By October 31, 2025: All companies must pre-register substances via the Chemical Registration System (KKS) and join the appropriate Substance Information Exchange Forum (SIEF).
New substances: For substances first placed on the Turkish market after October 31, 2025, pre-registration must occur within 30 days of market entry.

Lead registrant designation

By December 31, 2025: Lead registrants must be determined for substances already on the market prior to the announcement.
Newly introduced substances: the lead registrant must be appointed within 6 months.
The lead registrant is responsible for coordinating SIEF communications, including data sharing, tonnage bands and data gap analysis - with SIEF majority approval required.

Full registration deadlines

Substances subject to KKDIK registration must be fully registered via KKS by tiered deadlines based on tonnage and hazard profile:

Deadline
31 December 2026	Substances manufactured or imported ≥ 1000 tonnes/year Or classified as CMR (Carcinogenic, Mutagenic, or Reprotoxic) Category 1A or 1B ≥ 1 tonne/year OR substances classified as very toxic to aquatic organisms (Acute 1 or Chronic ) ≥ 100 tonnes/year
31 December 2028	Substances manufactured or imported at 100–1000 tonnes/year
31 December 2030	Substances manufactured or imported at 1–100 tonnes/year

However, there are transitional registration requirements in place:

If a lead registrant fails to submit a full dossier, a provisional dataset must be submitted by March 31, 2026, to initiate a transitional registration.
Member registrants must then submit their provisional dossiers by September 30, 2026.
Opt-out registrants must also submit Annex-1 data via KKS by March 31, 2026, if full registration obligations are not met.
Companies that complete full registration by March 31, 2026, are exempt from transitional provisions.
Registration fees will be due during this transitional phase.

New support structures

To support this complex regulatory rollout, two expert advisory bodies will be established:

Chemicals Science Group: Comprised of academic experts to assess chemical impacts on health and the environment.
Chemicals Advisory Group: Led by the General Directorate of Environmental Management to oversee chemical management strategies and evaluate implementation progress.

Safety Data Sheets (SDS) and Poison Centre Notifications (PCN)

All SDS prepared under Annex 2 of KKDIK must be uploaded via the Ministry’s designated SDS system by suppliers based in Türkiye.

As part of efforts to align with chemical safety standards, the Ministry released a draft amendment to the SEA Regulation introducing Poison Centre Notification obligations under Article 44/A. Whilst this marks a significant regulatory development, official guidance on implementation is yet to be released. Ricardo’s Notification Team is monitoring this closely and can provide support as further details emerge.

For more information on how to place on the market in Turkey click here.

Stay ahead: compliance, budgeting and supply chain continuity

KKDIK is not just about submitting data – it's about strategic planning. Businesses that act now will benefit by:

Avoiding compliance risks and penalties
Budgeting proactively for data-sharing, registration fees, and expert support
Preventing supply chain disruptions due to non-compliant substances or delayed registrations

If you're unsure how KKDIK impacts your business – or your downstream partners – now is the time to take action.

How we can help

At Ricardo, we provide tailored support to ensure your business:

Understands and meets all KKDIK deadlines
Coordinates data-sharing and SIEF communications
Manages costs effectively and avoids unnecessary
Keeps your products on the Turkish market without disruption
Support with authoring SDS and arranging stamping for Turkey.

Contact our REACH team to begin your compliance planning. Our experts are ready to guide you through every stage – from pre-registration to full dossier submission.

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