News Brief
The Directorate-General for Environmental Management of the Ministry of Environment, Urbanization and Climate Change (MoEUCC) has recently issued an official letter. The circular sends an extremely clear signal to those involved in the global chemical trade: KKDİK's temporary registration is mandatory for all enterprises that do not formally register substances.
Due to the absence of the lead registrant (LR), the official officially opened the individual temporary registration channel, allowing companies to complete compliance by September 30, 2026.
Regulatory Shift: Temporary Registration Becomes Mandatory
In the previous implementation process, many enterprises were in a wait-and-see state because the leading registrant (LR) was not selected for the substance. This official announcement clearly breaks this deadlock:
Temporary registration no longer relies solely on LR: it is officially clear that enterprises can no longer postpone registration on the grounds of "no LR" or "difficult industry coordination.
Official new rules: open individual temporary registration, even in the case of industry collaboration failure, enterprises can not through joint submission, but to complete the temporary registration by way of individual submission. Officials have added functions to the KKS system.
Key Deadlines: Critical Compliance Timeline for 2026
The time node is clearer and the window period is limited:
Deadline for lead registrants: temporary registration must be submitted before March 31, 2026, unless they have completed full registration. This is a prerequisite to ensure smooth follow-up by other SIEF members.
Deadline for joint submission members and individual temporary registrants: all relevant enterprises must finalize their interim registration by September 30, 2026, whether on an individual or joint submission basis, unless they have already completed a full registration.
Company Action Plan: Choosing the Right Registration Strategy
The enterprise shall take the following differentiated countermeasures according to the actual situation of the SIEF:
If the LR submits a temporary registration or full registration: enterprises must either joint submission or individul submission following the completion of the temporary registration or full registration by September 30, 2026
If there is no LR or LR inaction: enterprises should decisively use the new policy to complete temporary registration before September 30, 2026 by means of individual registration.
In short, as of 30 September 2026, only companies possessing a temporary or full registration number will be permitted to trade in Turkey in accordance with regulations.
REACH24H’s suggestion: take the initiative to avoid risks, LR status is better than a individual submission.
Businesses should verify the LR status of the substance on hand. For the LR that has not acted, it should be urged to declare its position as soon as possible. If the other party cannot cooperate, the enterprise should immediately start the individual registration plan.
Submitting as LR is the optimal solution for temporary registration compliance of enterprises: in the absence of LR, it is recommended that enterprises apply for LR identity first. Compared with single submission, LR mode can not only give enterprises 100 percent of the progress control, but also have a say in the subsequent data sharing while ensuring the certainty of compliance.
For more information or assistance, please feel free to contact us at customer@reach24h.com.
