On 12 August 2025, the Ministry of Environment, Urbanisation and Climate Change of the Republic of Türkiye published the Procedures and Principles Regarding the Implementation of the KKDIK Regulation.
With the publication of these Procedures and Principles, important updates have been introduced to the KKDIK compliance process. These are summarised below:
1 – Pre-Registration Deadlines Have Been Revised.
According to the new provisions, the final deadline for pre-registration is 31 October 2025. Pre-registrations must be submitted to the Ministry via the Chemical Registration System (KKS) and companies must become SIEF participants by this manner. For substances manufactured or imported after 31 October 2025, pre-registration must be completed within 30 days following the placing on the market.
2 – Deadline Set for Determining the Lead Registrant.
If a substance was placed on the market before the publication of the Procedures and Principles, the lead registrant must be determined by 31 December 2025 at the latest. For substances placed on the market for the first time after the publication, the lead registrant must be determined within 6 months.
3 – Temporary Registration Process Planned.
If the lead registrant is unable to fulfil the obligations regarding full registration, a temporary registration must be submitted by 31 March 2026.
The following information must be provided for temporary registration:
- Identification (KKS Section 1.1
1.1 Composition (KKS Section 1.2)
1.2 Analytical Information (KKS Section 1.4)
1.3 Suppliers – companies shall enter the names of their downstream users and keep this information up to date. This update is free of charge. (KKS Section 1.7)
1.4 Joint Submission (KKS Section 1.5)
- Globally Harmonised System (KKS Section 2.1)
- Manufacture, Use and Exposure (KKS Section 3)
3.1 Estimated Quantities (KKS Section 3.2)
3.2 Sites (KKS Section 3.3)
3.3 Information on Mixtures (KKS Section 3.4)
3.4 Use and Exposure Information (KKS Section 3.5)
3.5 Uses Advised Against (KKS Section 3.6) - Physical and Chemical Properties (KKS Section 4)
- Guidance on Safe Use (KKS Section 11)
Once the lead registrant completes the temporary registration, joint registrants must also submit their temporary registrations to the Ministry by 30 September 2026.
Companies that withdraw from the joint registration and cannot fulfil the requirements of full registration must also submit the data listed in Annex-1 of the Procedures and Principles via KKS by 31 March 2026 for temporary registration. However, these deadlines do not apply to companies that submit their full registration dossier by 31 March 2026.
4 – Establishment of Expert Advisory System.
The Procedures and Principles stipulate the establishment of a Chemicals Science Group consisting of academics from universities. This group will provide scientific support to the registration process by assessing the effects of chemicals on human health and the environment.
Additionally, a Chemicals Advisory Group will be established under the General Directorate of Environmental Management. This group will define and oversee plans, policies, strategies, and actions related to chemicals management.
5 – Special Software Package for Safety Data Sheets.
Safety Data Sheets (SDSs) prepared in compliance with the Annex II of the KKDIK Regulation must be uploaded by suppliers established in Türkiye into the Ministry’s dedicated SDS software package.
What Should Companies Do?
To comply with the changes introduced in the KKDIK process, companies must adhere to the specified deadlines. It is strongly recommended that companies initiate the necessary procedures without delay to avoid potential risks and seek support from qualified professionals.
You can review the Procedures and Principles by clicking here, or benefit from the checklist prepared by Chemleg.
| Task | Deadline/Period | Explanation | Check |
| Was the pre-SIEF notification submitted? | 31 October 2025 | Pre-registration must be submitted via KKS for existing substances. | |
| Was pre-registration completed for new substances? | Within 30 days after placing on the market. | Required for substances manufactured/imported for the first time after 31 October 2025. | |
| Has the lead registrant been elected? | 31 December 2025 | SIEF lead must be designated voluntarily. | |
| Was the lead registrant elected for new substances? | Within 6 months after placing on the market. | Applies to substances first placed on the market after publication of the Procedures and Principles (P&P). | |
| Did the lead company submit temporary registration data? | 31 March 2026 | If full registration cannot be submitted, P&P Annex-1 data must be entered into the system. | |
| Did co-registrants complete temporary registration? | 30 September 2026 | Temporary registration must be completed for SIEF members. | |
| Did all registrants submit CAE (Chemical Assessment Expert) reviewed data? | 31 March 2026 for lead & individual registrants – 30 September 2026 for co-registrants | Approved data must be entered into the system by the CAE. | |
| Have SDSs been prepared and uploaded? | Continuous | SDSs prepared in line with the Regulation must be uploaded into the system. | |
| Are all registration details up to date? | Within 3 months after any change | Updates must be made in case of changes in hazard information, use or company information, new information on risks, etc. | |
| Was an extension request submitted if needed? | Within registration period | Possible to obtain up to 2 years extension for missing data or technical justification. |
Expert Support from Chemleg
To ensure the KKDIK registration process progresses correctly and in full legal compliance, you can seek support from Chemleg experts.
Contact us by filling in the form now.
