Turkey Releases Detailed Implementation Rules for KKDIK

On August 12, 2025, the Turkish Ministry of Environment, Urbanisation and Climate Change (MoEUCC) formally adopted the “Regulation on the Procedures and Principles for the Implementation of the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (KKDIK)”, providing operational details and a clear timetable for putting KKDIK into practice.

Regulatory Background

KKDIK – often referred to as “Turkish REACH” – mirrors the EU REACH Regulation. It governs the registration, evaluation, authorisation, and restriction of chemicals and has been in force since January 2021. In January 2025, the MoEUCC released a draft of these implementing rules and invited public comments.

Key Provisions

1. Pre-registration deadline

• All registrants must submit a pre-registration via the Chemical Registration System (KSS) to MoEUCC by October 31, 2025, and become members of the relevant SIEF.
  
• Substances manufactured and/or imported for the first time after October 31, 2025, must be pre-registered within 30 days of being placed on the market.

2. Lead Registrant (LR) designation

• For substances already on the market before the publication of the Procedures and Principles, the LR must be designated by December 31, 2025. For substances placed on the market for the first time after publication, the LR must be designated within six months.
  
• After a candidate LR issues a notification, all SIEF members have 30 days to express support or opposition; the outcome is decided by a simple majority.
  
• For substances whose registration dossier has not yet been submitted, the LR must coordinate SIEF communication on tonnage band, data-gap analysis, and any agreements. These points must be accepted by a majority of SIEF members; otherwise, a new LR election is triggered.
  
• If a company currently acting as LR for a registered substance can no longer fulfil the role, it must inform all SIEF members and submit a written request with the necessary information and documents to MoEUCC. After the MoEUCC’s assessment, the system will allow the selection of a new LR. The outgoing LR is obliged to hand over all necessary information and documents to the new LR within 30 days of the MoEUCC’s written approval.

3. Transitional registration

• If the LR is unable to fulfil the obligation to submit a full registration, it must file a transitional registration with the MoEUCC by March 31, 2026, using the data specified in Annex 1 of the Procedures and Principles. After the LR has completed its transitional registration, member companies must submit their own transitional registrations by September 20, 2026.
  
• Companies that opt out of joint submission and intend to submit their own dossiers but are unable to complete a full registration must likewise file a transitional registration via KSS by March 31, 2026.
  
• The provisions above do not apply to companies that will submit a full registration before March 31, 2026.
  
• Full official fees must be paid to MoEUCC when a transitional registration is submitted.

4. Safety Data Sheets (SDS)

• SDS prepared in accordance with Turkish regulations must be uploaded by suppliers into the ministry-designated SDS software package.

CIRS Insights

The publication of these detailed implementing rules signals Turkey’s further alignment of its chemicals management system with international standards. With the pre-registration deadline of October 31, 2025, rapidly approaching, CIRS recommends that companies immediately initiate KKDIK pre-registration for substances exported to Turkey and confirm their registration intentions. Companies already designated as LRs should start the full registration process without delay.

Get your KKDIK questions answered in London

While the adoption of the “Procedures and Principles” marks a critical milestone for companies exporting chemicals to Turkey, many practical questions remain around enforcement, timelines, and compliance strategies.

To help industry stakeholders navigate these challenges, Elif Koç, General Manager of CHEMLEG Consultancy, will be presenting “Enforcing Chemical Compliance in Türkiye: Implications of the 2025 KKDIK Framework” at the CIRS Global Chemical Regulation Conference in London on 24 September 2025.

As both a speaker and event sponsor, Elif and her colleagues from CHEMLEG will also be available throughout the day to discuss company-specific KKDIK questions. This session will provide a timely opportunity to hear expert perspectives and prepare for the upcoming deadlines. You can find out more here and take advantage of early bird pricing until August 31!

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

Gov.