On this page
- KKDIK registration deadlines at a glance
- How the KKDIK deadlines reached their current form
- Which substances fall in the 31 December 2026 band
- What the 30 September 2026 temporary registration step changed
- What happens if a deadline is missed
- The two year extension and its limits
- Planning for the 2028 and 2030 bands
- What foreign suppliers should do before the end of 2026
Turkey's chemicals regulation, KKDIK, now has three full registration deadlines: 31 December 2026, 31 December 2028 and 31 December 2030, depending on tonnage and hazard. In front of them sits a temporary registration step that closed on 30 September 2026. This article sets out every date as it stands in October 2026, which substances fall into the first band, and what foreign suppliers should do now.
KKDIK registration deadlines at a glance
| Deadline | Step | Status in October 2026 |
|---|---|---|
| 31 October 2025 | Pre-registration (pre-MBDF) in KKS for substances already on the Turkish market | Passed |
| 30 days after first placing on the market | Pre-registration for substances placed on the market after 31 October 2025 | Rolling |
| 31 December 2025 | Lead registrant designation for existing substances | Passed |
| 31 March 2026 | Temporary registration by lead registrants | Passed |
| 30 September 2026 | Temporary registration by members, or individual temporary registration | Passed; Ministry checks under way |
| 31 December 2026 | Full registration, first band | About two months away |
| 31 December 2028 | Full registration, 100 tonnes or more per year | Open |
| 31 December 2030 | Full registration, 1 tonne or more per year | Open |
Tonnage is counted per registrant and per year. For an importer that is its own import volume. For an only representative, it is the combined volume of the importers it covers.
How the KKDIK deadlines reached their current form
The KKDIK Regulation was published in the Official Gazette on 23 June 2017 (No. 30105, duplicate issue). It originally required pre-registration by 31 December 2020 and full registration of all substances at 1 tonne or more per year by 31 December 2023. That single deadline proved unrealistic. Many substance forums had no lead registrant and few dossiers were ready.
The amendment published on 23 December 2023 (Official Gazette No. 32408) replaced the single date with three bands, following the EU REACH approach of registering the highest volume and most hazardous substances first. It also left the pre-registration timing to procedures to be issued by the Ministry.
Those procedures arrived in August 2025, when the Ministry of Environment, Urbanisation and Climate Change issued the Procedures and Principles for implementing KKDIK. They set the 31 October 2025 pre-registration date, the lead registrant timetable and the temporary registration route. KKS reopened for registration dossiers in November 2025.
In March 2026 the Ministry announced that temporary registration was mandatory for all registrable substances and opened an individual temporary registration route. Companies in forums with no active lead registrant could file alone, with a justification, by 30 September 2026. A Ministry letter of September 2026 repeated the date and said the Ministry would then check that manufactured and imported substances hold a temporary or full registration number.
Which substances fall in the 31 December 2026 band
Provisional Article 2 of KKDIK, as amended in 2023, puts three groups in the first band.
- Substances manufactured or imported at 1,000 tonnes or more per year.
- Substances at 100 tonnes or more per year classified as Aquatic Acute 1 or Aquatic Chronic 1 (H400, H410).
- Substances at 1 tonne or more per year classified as carcinogenic, mutagenic or toxic for reproduction, Category 1A or 1B.
Classification here means classification under Turkey's SEA regulation, which follows EU CLP. A substance with a harmonised CMR classification in CLP Annex VI, such as formaldehyde (Carc. 1B) or boric acid (Repr. 1B), will normally be in the first band from the first tonne. Self-classification counts too, so a substance your own SDS classifies as Repr. 1B is a first band substance even without a harmonised entry.
The bands are applied "without prejudice" to each other. A CMR substance imported at 50 tonnes is a 2026 substance, not a 2030 one, even though its tonnage alone would place it in the last band.
What the 30 September 2026 temporary registration step changed
Temporary registration is a Turkish feature with no direct EU equivalent. It lets a substance stay on the market while the full dossier is completed, provided a basic data set is in KKS. That data set is listed in Annex 1 of the Procedures and Principles and covers identity, classification and labelling, manufacture, uses and exposure, physical and chemical properties, and safe use guidance. A certified Chemical Assessment Expert (KDU) has to enter it, and the Ministry fee is paid at that point.
After a temporary registration, the full dossier is still due by the tonnage band deadline. The temporary step did not move the 2026, 2028 or 2030 dates. It added an earlier checkpoint so the Ministry can build its national inventory and see who is on the market.
For foreign manufacturers, the practical effect is that a Turkish customer may now refuse to order unless you can show a temporary or full registration number, either theirs or one held by your only representative in Turkey.
What happens if a deadline is missed
KKDIK follows the "no data, no market" principle. A substance that should be registered and is not may not be manufactured or imported. The Ministry has said it will run checks for registration numbers after 30 September 2026. Breaches of environmental regulations can lead to administrative sanctions under the Environmental Law No. 2872, and the more immediate risk for exporters is commercial: importers stop ordering.
As of late September 2026, we found no customs instruction requiring the KKDIK number on the import declaration, so enforcement is expected to come mainly through Ministry inspections of manufacturers and importers rather than at the border. This can change, and we check it before advising on a shipment.
If you have missed pre-registration or temporary registration, do not assume the route is closed. The answer depends on whether the substance was already on the Turkish market, whether a lead registrant exists, and what the Ministry accepts for late entrants at the time. It needs a case-by-case check in KKS and with the Ministry's Chemicals Help Desk.
The two year extension and its limits
The Procedures and Principles allow an extension when the data needed for a full dossier cannot be obtained in time, typically because studies are not available from public, free sources and the owners will not license them, or new testing is required. The lead registrant, or an individual registrant, files a reasoned request through KKS. The Ministry reviews it and may ask for more information.
Any extension cannot exceed two years after the final deadline for the relevant tonnage band. If the data is still missing at the end of the extension, the Chemicals Advisory Group reviews the case and the Ministry decides whether to accept or reject the registration. The extension is not a general postponement. It is case-specific and depends on documented data gaps.
Planning for the 2028 and 2030 bands
Four years sounds like plenty of time for a 2030 substance. In practice the work that takes longest sits outside your control.
- Letters of access. Lead registrants set prices and terms. Negotiation, especially for data owned by EU consortia, can take months.
- Data gaps. At 100 tonnes or more per year, Annex 9 testing proposals are needed. Some studies take a year or more to run.
- Tonnage creep. Business growth can push a substance into a higher band and an earlier deadline. A registrant must notify the Ministry within 20 working days of reaching the next threshold.
- Chemical safety report. From 10 tonnes per year, a chemical safety assessment is needed, with exposure scenarios that later go into the SDS.
Much of the data may already exist in your EU REACH dossier. Our comparison of KKDIK and EU REACH explains what can be reused and what licences you need for Turkey.
What foreign suppliers should do before the end of 2026
- List every substance you export to Turkey, alone or in mixtures, with annual volumes for the last three years.
- Check the classification of each substance for CMR 1A or 1B and for Aquatic Acute 1 or Chronic 1, and mark the first band substances.
- Confirm who holds the pre-registration and temporary registration for each substance: your importers, an only representative, or nobody.
- For first band substances, contact the lead registrant now about the full dossier and letter of access terms.
- Make sure your Turkish customers have a Turkish SDS prepared by a KDU, updated with the registration number when it is issued.
Our KKDIK registration service covers each of these steps for foreign manufacturers and Turkish importers.
Ekol Çevre engineering team
Environmental engineers and consultants based in İzmir, Ankara and Kocaeli.