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KKDIK Deadlines

Under the Turkish REACH Regulation (KKDIK – By-law No. 30105, dated 23 June 2017), all manufacturers and importers placing substances on the Turkish market are required to complete their registration obligations within defined timelines.

1. Temporary Registration Deadline (Critical – 2026 Update)

According to the Ministry of Environment, Urbanization and Climate Change (MoEUCC):

  • All substances must have a Temporary Registration (Individual or Joint) or Full Registration by:

    ➡ 30 September 2026

  • This requirement applies:
    • Regardless of tonnage band
    • Regardless of Lead Registrant availability
  • After this date:
    • Companies must hold a valid registration number to legally manufacture or import substances in Türkiye.
    • Substances without registration will be considered non-compliant and subject to enforcement actions.
  • For substances manufactured or imported after 30 September 2026:
    • Registration (temporary or full) must be completed before placing on the market.

2. Full Registration Deadlines (Based on Tonnage & Hazard)

Following temporary registration, companies must complete their full KKDIK registration according to the tonnage band and hazard classification:

    Tonnage / Classification Deadline
    ≥ 1000 t/y 31 December 2026
    ≥ 100 t/y + Aquatic Toxic (H400/H410) 31 December 2026
    ≥ 1 t/y + CMR (Cat. 1A/1B) 31 December 2026
    100 – 1000 t/y 31 December 2028
    1 – 100 t/y 31 December 2030

    3. Individual Temporary Registration (ITR) – Strategic Alternative

    To address these challenges, the Ministry introduced Individual Temporary Registration (ITR):

    • Does not require Letter of Access (LoA)
    • Can proceed independently of the Lead Registrant
    • Allows submission with justified data gaps (Annex-1 justification)
    • Enables companies to:
      • Secure compliance before 30 September 2026
      • Update dossiers later during full registration phase
    • If required data cannot be obtained:
      • Additional time (up to 2 years) may be granted for completion, subject to Ministry evaluation.

    5. Compliance Strategy Recommendation

    Given the current regulatory landscape:

    • If Lead Registrant dossier is available and cost-effective → Joint Registration may be preferred
    • If no Lead, delays, or high costs → Individual Temporary Registration (ITR) is strongly recommended

    ➡ The key objective is to secure a valid registration number before 30 September 2026 to avoid business disruption.

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