KKDIK Registration Services for Non-Turkish Manufacturers and Importers

KKDIK registration for substances sold into Turkey

KKDIK registration is the legal condition for manufacturing or importing a chemical substance in Turkey at 1 tonne or more per year. If you are a non-Turkish manufacturer, your Turkish customers cannot keep buying from you unless the substance is registered, either by each importer or by an only representative acting for you. We run the whole process from Turkey, in Turkish, directly with the Ministry and the substance forums.

This page explains where the deadlines stand in October 2026, what a registration involves, what drives the cost, and how we work for foreign companies and Turkish importers.

What KKDIK registration is

KKDIK is Turkey's chemicals regulation modelled on EU REACH. Registration means submitting a technical dossier on a substance to the Ministry of Environment, Urbanisation and Climate Change through the Chemical Registration System (KKS). It applies per legal entity, per substance, for quantities of 1 tonne or more per year, whether the substance is on its own, in a mixture or in certain articles.

The legal basis is the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (Kimyasalların Kaydı, Değerlendirilmesi, İzni ve Kısıtlanması Hakkında Yönetmelik), published in the Official Gazette on 23 June 2017, No. 30105 (duplicate issue). It was amended in November 2019 (No. 30963) and again on 23 December 2023 (No. 32408), which set the current tonnage band deadlines. The Ministry then issued the Procedures and Principles for implementing KKDIK in August 2025, which define pre-registration, lead registrant selection and temporary registration.

Who has to register under KKDIK

The registration duty sits with legal entities established in Turkey. In practice this means three groups.

• Turkish manufacturers producing a substance at 1 tonne or more per year.
• Turkish importers bringing in a substance, alone or in a mixture, at 1 tonne or more per year. Each importer counts its own volume.
• Only representatives appointed by a non-Turkish manufacturer, formulator or article producer under Article 9 of KKDIK. The only representative takes over the importer obligations, and the importers in that supply chain become downstream users.

A non-Turkish company cannot register in its own name. It either leaves the duty to every importer, or it appoints an only representative in Turkey who holds one registration covering all of its Turkish customers. For exporters with several Turkish distributors, the second option is usually cheaper and keeps the composition data confidential.

Substances already covered by other regimes, such as active substances in plant protection and biocidal products, are regarded as registered for those uses. Polymers are exempt, but their monomers may not be. Isolated intermediates follow reduced requirements under Articles 17 and 18.

KKDIK registration deadlines as of October 2026

The 2023 amendment replaced the original single deadline of 31 December 2023 with three tonnage and hazard bands. The Procedures and Principles added pre-registration, lead registrant and temporary registration dates in front of them.

Where data cannot be obtained in time, the lead registrant or an individual registrant can ask for more time through KKS with a reasoned request. Any extension granted by the Ministry cannot go beyond two years after the final deadline for that tonnage band. For a detailed reading of each date, see our article on KKDIK registration deadlines.

The 30 September 2026 temporary registration step

In March 2026 the Ministry announced that temporary registration is mandatory for every registrable substance and opened an individual temporary registration route in KKS. This was a response to forums where no lead registrant had come forward. A registrant could file alone, with a stated justification, by 30 September 2026.

A temporary registration contains the basic data set listed in Annex 1 of the Procedures and Principles: identity, classification, uses and exposure, physical and chemical properties and safe use guidance. The data entry must be made by a certified Chemical Assessment Expert (KDU), whose certificate is attached, and the official fee is paid at this stage. The Ministry has said that after 30 September 2026 it will check whether substances manufactured or imported in Turkey hold a temporary or full registration number.

If you missed pre-registration or temporary registration

Many foreign suppliers only hear about KKDIK when a Turkish customer asks for a registration number. If your substance was already sold into Turkey and neither you nor your importer filed by 30 September 2026, the position needs to be assessed case by case. Substances placed on the Turkish market for the first time after 31 October 2025 follow the 30 day pre-registration rule, and the Ministry expects a registration number to be in place before manufacture or import continues. We check the status of the substance in KKS, confirm the current practice with the Ministry's Chemicals Help Desk, and set out the fastest compliant route in writing.

How KKDIK registration works in practice

KKDIK follows the "one substance, one registration" principle. All registrants of the same substance are placed in a substance information exchange forum, called an MBDF (Madde Bilgi Değişim Formu, the Turkish equivalent of a SIEF). The forum agrees on substance sameness, chooses a lead registrant and shares data and costs.

1. Pre-registration. Each potential registrant submits substance identity and its role in the supply chain through KKS and joins the MBDF.
2. Lead registrant selection. A candidate notifies members through KKS. Members respond within 30 days, and the candidate needs a majority to be confirmed. If nobody volunteers, the Ministry designates one after consulting TOBB (the Union of Chambers and Commodity Exchanges of Turkey).
3. Joint submission. Under Article 12, the lead registrant submits the shared part of the dossier: classification and labelling, study summaries, detailed study summaries where needed, and testing proposals. Each member then files its own part, covering company identity, substance identity, uses and, at 1 to 10 tonnes, exposure information.
4. Letter of access. Members buy the right to refer to the lead dossier through a letter of access (LoA). The price is set by the lead registrant or the data owners, usually scaled by tonnage band.
5. Submission and fee. The member dossier is submitted in KKS, the Ministry fee is paid, and a registration number is issued.

A registrant may opt out of parts of the joint submission only on the grounds listed in Article 12(3): disproportionate cost, serious commercial harm from disclosure, or disagreement with the lead on data selection. The reasons must be filed with the dossier.

KKS sits inside the Ministry's Integrated Environmental Information System (ECBS). The dossier structure follows the IUCLID section logic used in the EU, which helps when EU data is available, but the Turkish dossier is a separate submission with its own identity, tonnage and use sections.

Data requirements by tonnage band

Article 13 of KKDIK sets the minimum information per tonnage band, per registrant. The annex numbers differ from EU REACH, but the content mirrors REACH Annexes VII to X.

When an existing registrant moves into a higher band, it must notify the Ministry within 20 working days of reaching the new threshold. Data waivers, read-across and QSAR predictions are accepted where Annex 11 conditions are met, and vertebrate testing is a last resort. Under Article 11, the dossier also carries a statement that the information was reviewed by a KDU certified under Annex 18, which is a Turkish feature with no EU equivalent.

Our KKDIK registration service

We act as your registration team in Turkey. The scope is set after a short inventory review, but a typical engagement covers the following.

• Regulatory screening of your product list: which substances are registrable, which are exempt, and which tonnage band each one falls into in Turkey.
• Pre-registration in KKS, MBDF membership and all forum correspondence in Turkish.
• Contact with the lead registrant or, where the forum is inactive, assessment of an individual or lead registrant route.
• Letter of access requests, cost sharing review and negotiation of the LoA terms, including territory and tonnage scope.
• Preparation of the member dossier, uses and exposure sections, and the KDU review statement.
• Submission, fee payment coordination and follow-up of Ministry questions.
• Only representative services for non-Turkish manufacturers, including the tonnage and customer records required by Article 9.
• Updates after the registration: tonnage band changes, new uses, new classifications, and Ministry evaluation requests.

Registration and SDS work are linked. Your Turkish customers need a Turkish SDS prepared by a KDU, and after registration that SDS must carry the registration number. Our Turkish SDS service runs alongside the registration so that both documents match.

How a KKDIK registration project runs

Durations below assume one to five substances with an active lead registrant. Forums without a lead, or substances with real data gaps, take longer.

1. Inventory and scoping, 1 to 2 weeks. We review CAS and EC numbers, compositions, annual volumes to Turkey and customer lists, then confirm obligations and the right registrant for each substance.
2. Appointment and access, 1 to 2 weeks. If you choose an only representative route, the appointment agreement is signed and KKS access is set up under our Turkish entity.
3. Pre-registration and forum contact, 1 to 3 weeks. We confirm or file the pre-registration, join the MBDF and request LoA terms from the lead registrant.
4. LoA negotiation, 2 to 8 weeks. This is the step that varies most. We check the price basis, what data the LoA covers, and whether a tonnage band discount or instalment option applies.
5. Dossier preparation, 2 to 6 weeks. We prepare the member dossier, uses and exposure information and, from 10 tonnes, the elements needed for the chemical safety report.
6. Submission and follow-up, 2 to 6 weeks. We submit in KKS, follow the Ministry's completeness checks, answer queries and send you the registration number with a short compliance file.

What we need from you

What drives the cost of KKDIK registration

We do not publish fixed prices because the main cost items are set by third parties. These are the factors that decide the total.

• Letter of access price. For most substances this is the largest single cost. It depends on the lead registrant's data costs, the number of co-registrants sharing them, and your tonnage band.
• Joint submission status. An active lead registrant with a complete dossier is the cheapest case. If the forum has no lead, or the lead dossier has gaps, costs rise because data has to be bought, generated or justified.
• Data ownership from EU REACH. EU consortia often own the key studies. An EU letter of access normally covers EU REACH only, so a separate licence for Turkey is needed. Some consortia sell a Turkey extension at a lower price than the original EU LoA.
• Tonnage band. Higher bands mean more data, a chemical safety report from 10 tonnes, and a higher LoA price.
• Ministry fees. KKDIK and SEA fees come from the Ministry's revolving fund unit price list, updated each January. The 2026 list was published on 12 January 2026.
• Number of substances and products. Several products often share a few registrable substances, so a careful inventory can reduce the count.

Comparing these costs with the value of your Turkish sales is part of the scoping step. For some low-volume substances, letting an importer register or reformulating can be the better business decision, and we say so.

How we act on your behalf in Turkey

Most of the friction in KKDIK work comes from language and access. Forum messages, Ministry letters, KKS screens and help desk answers are in Turkish, and many lead registrants are Turkish producers or consultancies that respond faster to a local call. We are based in Turkey, with offices in İzmir, Ankara and Kocaeli, and have worked on chemicals compliance (SDS, KKDIK and SEVESO) as part of more than 20 years in environmental consulting.

For non-Turkish manufacturers we can act as the appointed only representative, keep the volume and customer records the regulation requires, and report to you in English. For Turkish importers we prepare and submit the registration in your name. In both cases you receive the registration number, the submitted dossier summary and a list of the follow-up duties that come with it.

If you also need to compare your EU obligations with the Turkish ones, our article on KKDIK versus EU REACH explains where EU data can be reused and where it cannot.