SDS Requirements in Turkey Under KKDIK, a Guide for Suppliers

Safety data sheets for the Turkish market have to meet rules that go further than the EU's. Under the KKDIK Regulation, an SDS must be in Turkish, follow KKDIK Annex 2, be prepared by a certified Chemical Assessment Expert (KDU), and be uploaded to the Ministry's notification system. This guide covers when an SDS is required in Turkey, what it must contain, and the errors that most often lead Turkish customers to reject a sheet.

The legal basis for SDSs in Turkey

SDS rules sit in Part 4 of the KKDIK Regulation (Official Gazette of 23 June 2017, No. 30105), mainly in Article 27 and Annex 2. Classification comes from the SEA regulation on classification, labelling and packaging (Official Gazette of 11 December 2013, No. 28848), which is aligned with EU CLP.

Until the end of 2023, Turkey also had a separate SDS regulation from 13 December 2014 (No. 29204). Article 64 of KKDIK repealed it with effect from 31 December 2023. Since then there is one set of rules, and it requires a KDU. The Procedures and Principles issued by the Ministry in August 2025 added the upload duty and the KDU details in section 16.

When an SDS is required in Turkey

Under Article 27(1), the supplier must provide an SDS when:

• the substance or mixture meets the criteria for classification as hazardous under the SEA regulation;
• the substance is PBT or vPvB according to KKDIK Annex 13; or
• the substance is included in the candidate list under Article 49 for reasons other than the two above.

Under Article 27(3), a mixture that is not classified must still have an SDS supplied on request when it contains:

• at least one substance hazardous to health or the environment at 1% or more by weight (non-gaseous mixtures) or 0.2% or more by volume (gaseous mixtures);
• at least one substance classified as carcinogenic Category 2, toxic for reproduction Category 1, respiratory sensitiser Category 1, PBT or vPvB, or on the candidate list, at 0.1% or more by weight in a non-gaseous mixture; or
• a substance with a workplace exposure limit.

Hazardous products sold to the general public do not need an SDS if adequate safety information is given with the product, unless a downstream user or distributor asks for one. In practice, Turkish industrial buyers expect an SDS for every chemical product, classified or not.

Who may prepare a Turkish SDS

Article 27(1) states that the SDS is prepared by a Chemical Assessment Expert certified under Annex 18. The KDU completes Ministry-approved training (64 hours) and passes an exam with an accredited personnel certification body. The certificate is time-limited and must be renewed.

This has a direct consequence for foreign suppliers. An SDS written by your EU regulatory team and translated into Turkish does not meet the rule, however good the translation. A Turkish KDU has to prepare it and be named in it. Most exporters use a Turkish consultancy or their importer's KDU for this.

Format and content under KKDIK Annex 2

Article 27(6) requires the SDS to be dated and to carry 16 headings. Annex 2 sets the subsections and content, following the structure of EU REACH Annex II. The Turkish headings are fixed and should be used exactly.

Article 27(11) requires the classification in the SDS to follow the SEA regulation. Where the supplier must carry out a chemical safety assessment, from 10 tonnes per year, the relevant exposure scenarios are annexed to the SDS under Article 27(7), as with an extended SDS in the EU.

Turkish content is expected in several sections. Section 8 should give Turkish occupational exposure limits from the Regulation on Health and Safety Measures for Working with Chemicals (Official Gazette of 12 August 2013, No. 28733). Section 15 cites Turkish legislation. Section 16 must name the KDU, with contact details and the date and number of the KDU certificate.

Uploading SDSs to the Ministry system

The Procedures and Principles of August 2025 require suppliers to upload their SDSs, as electronic PDF files, to the SDS notification system run within the Ministry's Integrated Environmental Information System (ECBS). The upload is made from the Turkish supplier's account, so for imported products it is usually the importer or the only representative who files it.

If you supply several Turkish importers, each may upload the SDS for its own supply. Agree in advance who uploads which version, so that the Ministry does not hold sheets on different revision numbers for the same product.

Updating and distributing SDSs

Article 27(9) requires the supplier to update the SDS without delay when:

• new information becomes available that may affect risk management measures, or new information on hazards;
• an authorisation is granted or refused; or
• a restriction is imposed.

Under Article 27(10), the updated version goes free of charge, on paper or electronically, to every recipient supplied in the previous 12 months. Any update made after registration must include the KKDIK registration number. With the full registration deadlines on 31 December 2026, 2028 and 2030, most Turkish SDSs will need at least one update to add registration numbers.

Article 32 requires suppliers to keep the information needed for their KKDIK duties, SDSs included, for at least 10 years after they last supplied the product.

Are SDSs prepared before 2024 still valid

The Ministry's Chemicals Help Desk stated in February 2024 that SDSs prepared under the repealed 2014 regulation remain valid until an update is triggered. Once an update is needed, for example because of new hazard data, a change in composition or a KKDIK registration number, the revised SDS has to be prepared under Annex 2 by a KDU. Keep in mind that a new registration number is itself an update trigger, so most older sheets will be replaced within the registration period.

Common reasons Turkish SDSs are rejected

These are the problems we see most often when reviewing SDSs supplied by foreign companies to Turkish customers.

1. No KDU. The SDS is a translation with no KDU named in section 16, or the KDU certificate has expired.
2. EU-only content. Hazard statements from EU hazard classes added in 2023, which, as far as we could confirm, are not yet in the SEA regulation, or EU legislation listed in section 15 instead of Turkish rules.
3. Wrong exposure limits. German, UK or US limits in section 8 instead of Turkish values.
4. Foreign supplier only. Section 1 lists the foreign manufacturer but not the Turkish importer or only representative, and no Turkish emergency information.
5. Label mismatch. The Turkish label and section 2 show different pictograms or statements.
6. Outdated revision. The Turkish version is several revisions behind the master SDS.
7. Machine translation. Hazard and precautionary statements that do not match the official Turkish wording.

A checklist for foreign suppliers

1. List every product shipped to Turkey and decide which need an SDS under Article 27(1) and which on request under Article 27(3).
2. Arrange a Turkish SDS prepared by a KDU for each, based on your current master SDS.
3. Check classification against the SEA regulation and remove statements with no Turkish legal basis.
4. Agree with your importer or only representative who uploads the SDS to the Ministry system.
5. Align the Turkish label with section 2.
6. Plan updates for the KKDIK registration numbers as each substance is registered.

Our Turkish SDS service covers the KDU preparation, label text and upload, and our SDS authoring services keep your EU, GHS and Turkish versions on the same revision. For the registration side, see KKDIK registration.