What Is the KKDIK (Turkey REACH)

On June 23, 2017, Turkey’s Ministry of Environment, Urbanisation and Climate Change (MoEUCC) introduced the KKDIK regulation (Turkey REACH)—officially short for “Kimyasal Bileşiklerin Kayıt, Değerlendirme, Yetkilendirme ve Kısıtlama Yönetmeliği” (Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals).

Modeled closely after the EU REACH, KKDIK aims to regulate the safe use of chemicals in Turkey. Its core goals are to protect human health and the environment while ensuring transparency in chemical supply chains.

The KKDIK regulation came into force on December 23rd, 2017, and gradually replaced three older Turkish chemical laws:

• Regulation on the Inventory and Control of Chemicals, No.27092 (starting from June 23rd, 2017),

• Regulation on the Restrictions Relating to the Production, Supply to the Market and Use of Certain Hazardous Materials, Products and Goods, No.27092 (starting from December 23rd, 2017).

• Regulation on the Preparation and Distribution of Safety Datasheets for Hazardous Materials and Products, No.29204 (starting from December 31st, 2023)

Substances Subject to Turkey REACH Registration

Under KKDIK, registration is mandatory for any substance placed on the Turkish market in quantities of ≥ 1 tonne per year. This applies to three categories:

• Substances: Substances on their own manufactured in or imported into Turkey at ≥ 1 tonne per year;

• Mixtures: Substances contained in mixtures, where the individual substance is manufactured or imported at ≥ 1 tonne per year;

• Articles: Substances intended to be released from articles, where the total quantity of the substance placed on the Turkish market exceeds 1 tonne per year.

Exemptions

Certain categories of substances are exempt from KKDIK regulation/registration requirements, falling into three distinct groups:

1. Fully Exempt from the KKDIK Regulation

•  Radioactive substances

•  Substances subject to customs supervision

•  Substances for use in national defense

•  Wastes

•  Non-isolated intermediates

•  Carriage of hazardous substances by rail, road, inlandwaterway, sea or air

2. Exemptions from KKDIK Registration

•  Foods or feeding stuffs

•  Medicinal products

•  Substances included in Annex IV

•  Substances included in Annex V

•  Registered substances from the recovery process

•  Registered substances being re-imported

•  Polymers (monomers and other reactants need to be registered)

•  PPORD substances (subject to PPORD notification instead of registration)

3. Deemed Registered Substances

•  Active substances for use in Biocidal Products

•  Active substances for use in Plant Protection Products

Who Is Responsible for KKDIK Registration

The following entities are responsible for fulfilling KKDIK registration obligations:

1. Turkish-based manufacturers: Companies producing regulated substances within Turkey.

2. Turkish-based importers: Companies importing regulated substances, mixtures, or articles into Turkey.

3. Turkish Only Representatives (ORs): Third-party entities in Turkey appointed by non-Turkish manufacturers to fulfill registration requirements on their behalf.

Once the responsible entity has been determined, the registrant must complete the KKDIK registration process in accordance with the applicable procedural steps.

The KKDIK registration process is structured into three key stages: pre-registration, interim registration, and registration.

How Non-Turkish Manufacturers Can Comply with KKDIK

Non-Turkish manufacturers without a physical presence in Turkey are not permitted to submit KKDIK registration applications directly to Turkish regulatory authorities. Instead, they must engage a qualified Turkish entity to fulfill these obligations on their behalf.

Non-Turkish manufacturers may choose from the following three legally recognized pathways to comply with KKDIK:

Establish a Turkish Branch Office

Set up a locally registered legal entity to manage all KKDIK compliance activities, including registration dossier preparation, submission, and ongoing regulatory reporting.

Partner with a Turkish-Registered Importer

Collaborate with a Turkish-registered importer who will serve as the official KKDIK registrant for your products. This pathway requires sharing detailed technical data and confidential business information (CBI) with the importer, which may expose sensitive intellectual property and competitive trade secrets to third parties.

Appoint a Turkish Only Representative (OR)

Widely regarded as the most secure and efficient compliance solution. A Turkish OR acts as your exclusive legal proxy under KKDIK, assuming full statutory responsibility for all regulatory obligations, protecting your CBI in accordance with Turkish data protection laws, and eliminating the need for you to establish a local physical presence.

For professional, fully KKDIK-compliant Only Representative (OR) services tailored to your specific regulatory requirements, contact REACH24H.

Note: Non-Turkish traders are not eligible to appoint a Turkish OR for KKDIK registration under the regulation, as OR appointments are legally restricted to non-Turkish manufacturers.

KKDIK Registration Types

KKDIK Pre-Registration (Pre-SIEF)

Under Turkey REACH (KKDIK), pre-registration is required in order to benefit from the phased registration deadlines.

• For substances already placed on the Turkish market, companies must complete pre-registration by 31 October 2025.

• For substances first manufactured and/or imported after 31 October 2025, pre-registration must be completed within 30 days of the substance being placed on the market.

Interim Registration

Interim registration is a step between pre-registration and registration, allowing registrants to temporarily submit an incomplete dossier to advance the joint registration process. The interim registration only requires submitting physicochemical tests (listed in Annex I)

• Lead Registrants (if unable to file a complete dossier) and companies filing an individual submission: Must complete the interim registration by March 31, 2026.

• SIEF members: Must complete joint submission of interim registration by September 30, 2026.

 All companies must supplement all data by their tonnage band deadline and submit registration dossier.

KKDIK Registration

Under KKDIK, substances subject to registration must be registered by the following deadlines, depending on their annual tonnage band and hazard classification.

Per Turkish KKDIK regulatory requirements, the following must be noted for registration:

• Data Requirement: KKDIK registration data aligns with EU REACH. EU REACH data can be used for KKDIK, but re-obtaining data usage rights is mandatory.

• Language Rule: Study Summaries, Chemical Safety Reports (CSR), and Exposure Scenarios (ES) must be in Turkish.

• Qualified Personnel: Only Certified Chemical Assessment Specialists (CASs) are authorized to prepare dossiers, CSR, and SDS/eSDS.

• Joint Submission: Joint registration (Lead Registrant + Co-Registrants) is permitted.

Turkey REACH Registration Timeline & Deadline

KKDIK Registration Tools - KKS

All KKDIK registration activities (dossier preparation, submission, etc.) must be completed via the KKS Tool—MoEUCC’s official online platform. 

Note that the KKS Tool is only available in Turkish.

Other Key Obligations Under KKDIK (Turkey REACH)

Evaluation

The Ministry of Environment, Urbanisation and Climate Change (MoEUCC) oversees KKDIK evaluation, which includes two key activities:

1. Dossier evaluation: Review of registration dossiers to ensure compliance with data requirements.

2. Substance evaluation: Assessment of a substance’s risks to human health or the environment.

3. Outcomes of Evaluation：

MoEUCC may:

• Require additional data or further evaluation from registrants;

• Add the substance to the Authorization List (Annex XIV) or Restriction List (Annex XVII) if risks are unmanageable.

Authorization

Authorization governs the use of high-risk substances under KKDIK:

• Candidate List (SVHCs): Substances of Very High Concern (SVHCs) are flagged for potential inclusion in the Authorization List (Annex XIV).

• Authorization List (Annex XIV): Substances on this list cannot be manufactured, imported, or used in Turkey unless a company obtains explicit authorization from MoEUCC.

Restriction

Restrictions limit or prohibit specific uses of substances:

• Restriction List(Annex XVII): Substances included in the restriction list are restricted or banned for specific uses.

Other Key Chemical Regulations in Turkey

Turkey SDS Regulation

SDS regulation (No.29204) is replaced by KKDIK Annex II on December 31st, 2023. Suppliers of a substance or a mixture meeting certain conditions shall provide a safety data sheet (SDS) compiled in accordance with Annex II in Turkish. The SDS shall be prepared by a local certified chemical assessment specialist.

When an SDS Must Be Provided

Suppliers are required to provide an SDS for substances and mixtures in the following cases:

• Hazardous substances and mixtures classified under the Turkish SEA (CLP) Regulation;

• Substances meeting the PBT or vPvB criteria as defined in Annex XIII of KKDIK;

• Substances identified as Substances of Very High Concern (SVHC).

Turkey CLP Regulation

The Turkish SEA Regulation (No. 28848), also referred to as Turkey’s Classification, Labelling and Packaging (CLP) Regulation, governs the classification, labelling, and packaging of substances and mixtures. It entered into force in December 2013 and establishes the framework for identifying hazardous properties, communicating risks to users, and ensuring safe handling of chemicals in the Turkish market.

C&L (Classification & Labelling) Notification in Turkey

• For substances that are classified as hazardous ones, manufacturers or importers have to submit a C&L Notification to the Turkish competent authority to form the C&L inventory

• Non-Turkish manufacturers can appoint an OR to complete the C&L Notification

• For substances placed on the market after June 1st, 2015, the competent authority should be notified at least within one month after such substances are placed on the Turkish market for the first time 

• Submit through the KKS tool

Our Services

•  Turkish Only Representative(OR) Service

•  KKDIK Pre-registration Service

•  KKDIK Interim Registration Service

•  KKDIK Registration Service

•  SIEF Management

•  Testing Supervision

•  Safety Data Sheet (SDS) and Label Preparation (Turkish-language, CAS-certified)

•  Turkey C&L Notification

•  KKDIK Compliance Analysis

•  Consortium Support for Joint Registrations

For more information and inquiries on Turkey REACH, please feel free to contact us at customer@reach24h.com.