Turkey REACH KKDIK update: What's new, who's affected and how to comply

Kimyasalların Kaydı, Değerlendirilmesi, İzni ve Kısıtlanması Hakkında Yönetmelik, or KKDIK translates as the Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals. Published in Turkey’s Official Gazette on 23 June 2017 by the Ministry of Environment, Urbanization and Climate Change, it is Turkey’s primary legal framework for managing chemical substances across their entire lifecycle. 

KKDIK is modeled on EU REACH (Regulation (EC) No 1907/2006), and the structural parallels are deliberate: both regulations impose registration obligations on manufacturers and importers above a tonnage threshold, both include authorization and restriction mechanisms for substances of very high concern (SVHCs), and both allow non-domestic manufacturers to appoint an Only Representative (OR) to fulfil registration obligations on their behalf. 

However, KKDIK is a fully independent national regulation which, while sharing many similarities, is by no means identical to the EU REACH Regulation. Hence, EU REACH registration with the European Chemicals Agency (ECHA) does not satisfy KKDIK obligations in Turkey, just as REACH-compliant Safety Data Sheets cannot simply be translated into Turkish to comply with the KKDIK. The two systems operate in parallel, with separate competent authorities, separate registration portals, separate formatting and language requirements, and separate SVHC lists. Companies that are fully compliant under EU REACH must still assess and address their KKDIK exposure independently. 

Regulatory authority and enforcement body

The Turkish Ministry of Environment, Urbanization and Climate Change is the authority responsible for KKDIK implementation, oversight, and enforcement. Registration dossiers are submitted via the KKS (Kimyasal Kayıt Sistemi) portal, which is the functional equivalent of ECHA’s REACH-IT platform. All registration interactions such as submissions, queries, and compliance correspondence occur through Turkish institutional channels and in Turkish. 

Scope: what substances and activities are covered

KKDIK applies to substances manufactured in Turkey or imported into Turkey at, or above, one ton per year, whether as substances on their own, in mixtures, or, under certain conditions, in articles. The regulation covers four core pillars: registration, evaluation, authorization of SVHCs, and restriction of hazardous substances. Certain categories are excluded. 

For multinational compliance teams, the most operationally dangerous aspect of KKDIK is its similarity to EU REACH. Because the structural logic is familiar, it is tempting to assume that existing compliance infrastructure transfers, but largely, it does not. The differences that matter are specific, operational, and consequential for market access.

Where KKDIK and EU REACH align

Both KKDIK and EU REACH share the same foundational architecture. Registration obligations are triggered by annual tonnage thresholds. SVHCs are subject to authorization requirements. Restriction mechanisms exist for hazardous substances. Safety Data Sheets (SDSs) are required along the supply chain. And the Only Representative model, allowing a non-domestic manufacturer to appoint a local entity to fulfil registration obligations, is available under both systems. For compliance teams already operating under EU REACH, this shared logic provides a useful orientation framework. 

Who must comply with KKDIK?

KKDIK obligations rest with the legal entity placing a substance on the Turkish market. Your role in the supply chain determines your compliance requirements.

Turkish manufacturers producing chemical substances at one ton or more per year must register directly via the KKS portal, bearing full responsibility for dossier preparation. 

Turkish importers sourcing substances, alone or in mixtures, or in applicable articles, above one ton annually must also register. Where multiple importers source the same substance from the same foreign manufacturer, each is independently obligated unless a joint submission or Only Representative (OR) arrangement exists. Without coordination, this creates inconsistent compliance standards and risks exposing the supplier’s commercial data. 

Non-Turkish manufacturers have no direct registration obligation, it falls on their Turkish importer. However, they face a strategic choice: allow independent importer registrations, or appoint an Only Representative in Turkey. The OR model is typically preferred for protecting formulation confidentiality, centralizing compliance management, and maintaining consistent dossier quality.

Downstream users are generally exempt from registration but must confirm their uses are covered by a valid registration and reflected in the registrant’s Chemical Safety Report. Formulators importing mixtures above tonnage thresholds may trigger importer obligations and should assess their position carefully.

Failure to register a substance under KKDIK before the applicable deadline means that substance cannot legally be manufactured in or imported into Turkey. The consequence is market access loss. For B2B chemical suppliers, that means customer loss and supply chain disruption with immediate commercial impact.

What compliance dates to look out for

The KKDIK deadline landscape has fundamentally changed, following the latest update from the Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) on 6 March 2026. What was once a phased process with staggered timelines stretching to 2028 and 2030 has been replaced by a single hard deadline: 30 September 2026.

Every company manufacturing or importing substances into Turkey must obtain a valid registration number, provisional or full, by that date, regardless of tonnage band or Lead Registrant status. All registration submissions must be prepared in Turkish and validated by a certified Chemical Assessment Specialist (KDU). Pre-registration numbers will no longer be accepted, and unregistered substances will be barred from the Turkish market. There is no longer any room for a gradual approach.

However, there will still be some leeway with the individual provisional registration data requirements. Namely, if the company thinks they will not be able to prepare all Annex I of the 2025 KKDIK Procedures and Principles information before the September deadline, they can still submit a provisional registration so long they can justify and document their missing data in KKS – and provide it later when it becomes available, up to the applicable full registration deadline(s) (2026, 2028, or 2030).