Chemical Registration System – KKDIK – Registration, Evaluation, Authorization and Restriction of Chemicals

Are the chemicals you manufacture, import or ship to Türkiye registered in the Chemical Registration System?

The answer to this question may well determine whether your company can remain on the Turkish market from 2027 onwards…

Postponed for several years because the industry was not yet ready, the registration of chemicals is now in force. Companies that fail to register the chemicals they place on the market face serious risks.

To avoid enforcement action by the Ministry, customs barriers on your imports, and the loss of your existing customers and market share, register your chemicals without delay.

With 20 years of experience in the regulatory consultancy sector and a team of Chemical Safety Assessors, Lore Danışmanlık is ready to guide you through this complex process.

A guide to registration obligations for companies manufacturing, importing or using chemical substances in Türkiye.

What Is KKDİK?

KKDİK is the Turkish acronym for the “Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals”. It was published in the Official Gazette No. 30105 (repeated) dated 23 June 2017 and entered into force on 23 December 2017. The sole competent authority for the process is the Ministry of Environment, Urbanisation and Climate Change.

In essence, this regulation is the Turkish adaptation of the European Union’s REACH Regulation. Its purpose may fairly be summarised as “transferring the responsibility of proving that a chemical is safe from the state’s inspection mechanism to the company that manufactures or imports that chemical”.

For this reason, fulfilling the obligations arising from the regulation is of critical importance for companies importing chemical substances into Türkiye, for domestic manufacturers, and for companies selling chemical substances to Türkiye from abroad.

To make the subject and the procedures clearer, we have set out the key points you need to know.

Who Falls Within the Scope of KKDİK?

The registration obligation depends on the substance placed on the market through import or manufacture, on its quantity, and on your company’s role in the process. You are within scope if any of the following applies to you:

• Manufacturer: If you manufacture 1 tonne or more of a chemical substance per year in Türkiye.
• Importer: If you import 1 tonne or more of a chemical substance per year into Türkiye — on its own, in a mixture, or contained in an article.
• Only Representative: If you are a manufacturer established outside Türkiye and ship chemical substances to Türkiye, you may transfer the obligation by appointing an only representative established in Türkiye. This relieves your Turkish buyers of the importer’s obligation and protects your market.
• Downstream User and Distributor: You are not directly subject to the registration obligation; however, if your supplier is not registered, the raw material you use may disappear from your supply chain as of 2027.

Deadlines for Provisional Registration and Individual Provisional Registration

Under KKDİK, registration operates as a rule on the principle of joint registration. The system is built on companies placing the same substance on the market coming together, appointing a lead registrant among themselves, and then submitting a joint registration by sharing both the substance data and the cost.

The Procedures and Principles on the Implementation of the KKDİK Regulation, published on 5 August 2025, set this process to a fixed timetable:

What Happens If You Do Not Register?

The consequences under KKDİK are far more severe than a conventional administrative fine. The likely sanctions are as follows:

In order to identify the substances subject to registration, the SDS (Safety Data Sheet) of every chemical you trade in or manufacture must be obtained, and each product must be classified according to the substances it contains and the quantities in which they are used. The hazardous substances present in mixtures are then identified in accordance with the Regulation on Classification, Labelling and Packaging of Substances and Mixtures (the SEA Regulation, Türkiye’s CLP equivalent).

The chemical substances requiring registration are then determined by taking the average of the import / manufacture volumes of these substances over the past three years.