TURKEY KKDIK REGISTRATION UPDATE
Turkey's Ministry of Environment, Urbanization and Climate Change (MoEUCC) has clarified how companies should proceed with KKDIK registration after September 30, 2026. Its announcement, last updated on October 5, reports that more than 42,000 registration submissions had been sent to the Ministry by September 30. For a completed application that is awaiting a registration number, the corresponding application number may be used where needed until the registration number is assigned.
KKDIK governs the registration, evaluation, authorization and restriction of chemicals in Turkey. The Ministry's update confirms that the Chemical Registration System (KKS) will remain open. Technical work is underway to enable tonnage updates for interim dossiers and to receive extension requests for certain substances due for registration on December 31, 2026. These developments affect Turkish registrants, importers and overseas suppliers coordinating registration through an Only Representative (OR).
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Application Numbers May Be Used While Registration Numbers Are Pending
The Ministry’s clarification applies to substances for which the registration application has been completed, but a registration number has not yet been obtained. Where needed, the corresponding application number may be used until the registration number is issued.
Companies should retain the submission record and confirm that the reference shared with importers relates to the completed registration application. A pre-registration number is a separate reference and should not be confused with the application number covered by this announcement. The notice does not expressly guarantee customs clearance in every case, so suppliers should confirm the documentation required for their transaction with the Turkish importer and relevant authorities.
Where submission status or importer coverage is unclear, companies can review their arrangement with their registrant or OR. REACH24H's KKDIK registration and Only Representative services support registration pathway assessment, dossier submission tracking and coordination of importer coverage.
KKS Will Remain Open for Registrations and Dossier Updates
KKS will continue to support registration and notification activities under KKDIK and Turkey's SEA classification, labelling and packaging regulation. It will also receive new substance registrations, allow dossier updates and support completion of applications that did not receive a registration number because of system-related technical issues.
The Ministry reports that KKS generally operated without interruption during the registration process, with a limited number of technical errors. Continued system availability is an operational clarification; it does not, by itself, establish a general extension of registration deadlines or an exemption from applicable obligations.
Tonnage Updates and Extension Requests Await Further Instructions
For interim registration dossiers already submitted, the Ministry is carrying out technical work to enable tonnage updates in KKS. Companies needing to change tonnage information are instructed to wait for a further Ministry announcement. In the meantime, they should identify the affected substances and prepare accurate manufacture or import quantity records.
The Ministry is also developing the KKS infrastructure for extension requests concerning substances that have interim registration and a registration deadline of December 31, 2026. This deadline covers substances at 1,000 tonnes per year or more and specified high-hazard categories. Further information will be announced later. The announcement does not state that the deadline has been extended for all affected substances.
Existing procedures provide for conditional individual extension requests, potentially for up to two years, subject to the competent authority's decision. Companies should assess eligibility rather than assume that additional time has already been granted. For background on the applicable registration deadlines and the transition from interim registration, see the KKDIK individual interim registration guide.
Businesses facing data gaps or unresolved Letter of Access (LoA) arrangements should continue full registration preparation while monitoring the application channel. They should document the reasons for any proposed extension request and follow the Ministry's forthcoming instructions on submission.
Registration Fees Must Be Paid Within 15 Days of Submission
Companies submitting registration applications must pay the applicable administrative fees within 15 days following submission. Payment is made through Halkbank, and dossier review begins after payment.
Registrants should track the submission date, payment deadline and payment confirmation for each application. Overseas suppliers should coordinate with the Turkish registrant or OR early enough to avoid a payment delay holding up review. Submission and fee payment are distinct steps in the process.
Manufacture and Import Inspection Processes Are Being Prepared
The Ministry says work is continuing on manufacture and import inspection processes for companies with registration obligations. The announcement does not specify an inspection start date or detailed enforcement procedure.
What Companies Should Check Now
Companies should check that substance identity, tonnage, importer information and registration status are consistent across their records. For each substance supplied to Turkey, confirm whether the application is complete, whether fees have been paid and whether a registration number has been issued. Record any tonnage update needed and identify substances requiring full registration by December 31, 2026.
Further developments will be announced through the Ministry's website and Chemicals Helpdesk. Keeping submission evidence and supply-chain records current will help companies respond to document requests and prepare for the next registration steps.
REACH24H Support for the Next Registration Steps
REACH24H supports overseas manufacturers and regulatory teams with the following KKDIK services:
Registration obligation and pathway assessment: Review substance scope, annual tonnage, supply-chain roles and applicable deadlines to plan interim or full registration.
Only Representative and importer coverage: Coordinate Turkish OR arrangements, importer information, registration coverage and ongoing tonnage tracking.
Interim and full registration support: Assist with dossier preparation, Turkish-language documentation, KKS submission coordination, fee payment follow-up and submission status tracking.
Data and joint submission support: Assess EU REACH data reuse, identify data gaps, review Letter of Access arrangements and support data-sharing and joint submission coordination.
Review Your KKDIK Submission and Next Steps
Contact a REACH24H KKDIK specialist with your substance name, CAS or EC number, annual tonnage, Turkish importer details and current registration status to discuss the appropriate follow-up.
