Overview
Recently, Turkey officially released the latest announcement that the registration module in the KKDK Chemical Registration System (KKS) has been officially activated and supports the submission of "temporary registration" files.
The launch of this function means that the "Procedures and Principles for the Implementation of KKDIK Regulations" previously issued by the Ministry of Environment, Urbanization and Climate Change of Turkey (MoEUCC) has officially entered the practical stage.
For the majority of trade enterprises to Turkey, it means that there is no longer room to wait and see, and the compliance path must be locked immediately according to their own role (LR or MR).
Update: According to the official letter released by MoEUCC on April 3, 2026, 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.
What Is a Temporary Registration under KKDIK?
According to Article 10 of the "Regulations", if the lead registrant is currently unable to submit a formal registration, it must first submit a provisional registration before March 31, 2026. SIEF members are then required to complete a joint submission for provisional registration by September 30, 2026. Provisional registration only requires the submission of physicochemical data without the need to submit ecological and toxicological data for the time being.
The mechanism of provisional registration is not an "option", but a registration step with substantive requirements.
According to the latest announcement, the official further clarified the standard process and operation path of temporary registration:
Lead Registrant Responsibilities: Be Proactive in Turkey REACH
Being the lead registrant (LR) is a pioneer in ensuring the compliant circulation of substances in the Turkish market. In order to cope with the provisional registration deadline of March 31, 2026, LR must focus on the following key tasks:
Quickly identify LR status: Promote the election of SIEF members and recognition of their LR status to avoid process delays.
Lead SIEF protocol drafting and signing: Responsible for signing agreements with all potential registrants to establish the basis for data sharing and collaboration. All correspondence during the SIEF communication process must be properly kept so that it can be presented at any time upon official request.
Preparation of core data: Key information needs to be collected and submitted, especially physical and chemical properties.
Submission of registration documents: Temporary registration files must be submitted through the KKS system before March 31, 2026.
Prompt notification of potential registrants to submit provisional registration and cost sharing
Submitting as a Group: What Companies Should Know?
The joint submission compliance path has the characteristics of "passive follow", which requires continuous monitoring of LR status:
1. Enterprises should first ensure that the pre-registration of substances has been completed, which is a prerequisite for monitoring the status of LR registration within the KKS system.
2. The LR's options for action must be closely watched:
If the LR has completed a formal registration, the joint venture need not be provisionally registered, but need only complete the joint submission for formal registration before the corresponding tonnage deadline;
If the LR fails to complete the formal registration and submits the provisional registration, the joint enterprise must also complete the joint submission of the provisional registration by September 30, 2026.
What Matters Most to Your Company?
With the improvement of the functions of the KKS system and the approaching of the deadline, the fuzzy zone is disappearing. It is recommended that the relevant enterprises exporting to Turkey take the following actions immediately:
Confirm role and willingness: Enterprises intending to become LR need to make a final decision in the next few weeks to advance the SIEF communication process.
Monitor LR dynamics: Enterprises intending to jointly register should pay close attention to LR registration status and actively participate in SIEF communication and negotiation.
Prepare for temporary registration: The temporary registration system seems to reduce the pressure of formal registration, in essence, the start of formal registration is greatly advanced, the relevant export enterprises need to adjust compliance strategies and budget planning in a timely manner.
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