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The first key deadline, 31 March 2026, to submit the full or provisional KKDIK Lead Dossier, according to the KKDIK Procedures and Principles document published by the Turkish Ministry of Environment and Climate Change (MoEUCC) in August 2025, is rapidly approaching.

It is crucial for KKDIK Lead registrants to ensure that their full or provisional Lead Dossiers for the substances they intend to lead register – independent of their annual tonnage and classification – are submitted by the 31 March 2026 deadline.

Key Responsibilities of the KKDIK Lead Registrant (LR)

After compiling the necessary data for the full or provisional registration, the Lead Dossier must be submitted via the Chemical Registration System (KKS) by 31 March 2026.

Companies that cannot fulfill their full Lead Dossier requirements by this deadline may submit a provisional Lead registration dossier, covering the reduced data specified in Annex I of the KKDIK Procedures and Principles document. Submission of the provisional Lead Dossier will allow Lead registrant companies to complete their full dossier requirements by the applicable KKDIK registration deadlines for the substances they intend to register: 31 December 2026, 31 December 2028, or 31 December 2030, depending on the tonnage band and classification of the substance.

The data required for Lead registration must be provided in the Turkish language and signed off by a certified chemical assessment expert (KDU). Following submission, the MoEUCC will conduct a completeness check and provide the registration number. Registration fees will vary depending on company size and the annual tonnage band of the substance.

Please note that if your company has acted as a Lead Registrant under EU REACH for the substance intended for lead registration under KKDIK, the same dataset may be used to facilitate and expedite the KKDIK Lead registration submission process.

Why Is the Lead Registrant Submission Deadline So Critical?

The Lead Registrant plays a pivotal role in the KKDIK registration process and is responsible for compiling and submitting the core technical dossier to the MoEUCC. This dossier forms the foundation for joint registration under KKDIK.

If the LR fails to submit the full or provisional Lead Dossier by the end of March 2026, the joint registration process is disrupted, leaving co-registrants unable to submit their own dossiers. Without timely submission by the Lead Registrant, joint registration cannot proceed, impacting all co-registrants.

Consequences for Co-Registrants and the Entire Registration Process

If the full or provisional Lead Dossier is not submitted by the March 2026 deadline, several significant consequences may arise:

• No Joint Registration: Stand-alone submissions are not permitted under KKDIK. If the Lead Dossier (full or provisional) is not submitted on time, co-registration cannot proceed, as co-registrants rely on the Lead Registrant’s dossier for joint submission.
• Delays in the Registration Process: Substances may be considered non-compliant under KKDIK, risking market access, penalties, and supply chain disruptions.
• Increased Business Risk: Failure by the LR to meet the deadline leaves co-registrants unable to proceed, creating uncertainty across the supply chain. Missing the deadline can result in significant regulatory and business consequences for manufacturers, formulators, importers, Only Representatives in Türkiye, and other supply chain actors.

What Co-Registrants Need to Do Now

1. Engage with the Lead Registrant: Ensure that the appointed Lead Registrant for the substance you intend to co-register under KKDIK is actively working toward the March deadline. Confirm that the Lead Dossier will be submitted on time and that your data aligns with the required submission.
2. Review and Prepare Your Data: Begin preparing your data for co-registration. Ensure all necessary company and technical information is ready for inclusion in the joint registration dossier and that certified professionals are available to sign off on your dossier(s) where applicable. All information must be submitted in the Turkish language.

What KKDIK Lead Registrants Need to Do Now

1. Complete and Submit Your Lead Dossier: Prioritize completion and submission of the full or provisional Lead Dossier by the March 2026 deadline.
2. Coordinate with Co-Registrants: Work closely with co-registrants to ensure data alignment and maintain clear communication on timelines and any required changes.
3. Compile and Verify Data: Ensure that all required data are complete and accurate and signed off by a certified professional.
4. Manage Data-Sharing Agreements and Costs: Organize data-sharing agreements within your SIEF and ensure transparency and fairness in cost distribution for any new studies or data evaluations required under KKDIK.
5. Familiarize Yourself with the Submission Portal – KKS: Confirm that all technical requirements of the MoEUCC submission portal are met and test the system in advance to avoid last-minute issues.

Key Takeaways

• For Lead Registrants: Submitting the full or provisional Lead Dossier by March 2026 is essential for co-registration to proceed.
• For Co-Registrants: If the Lead Dossier is not submitted on time, joint registration will not be possible.
• For Manufacturers, Importers, Formulators, and appointed Only Representatives: The March 2026 deadline is critical. Ensure your Lead Registrant is on track and be prepared for potential delays or adjustments.

Don’t Wait! Act Now!

Timely submission of the Lead Dossier is essential for the success of the KKDIK registration process. If the LR misses the March deadline, co-registration will not be possible, and the ability to register will be at serious risk. Avoid market disruptions and legal consequences by acting now to remain compliant.

Whether you are a Lead Registrant or co-registrant, ensure you have the necessary expertise to complete the KKDIK registration process. If your company lacks in-house experts, contact a qualified and experienced KKDIK service provider.

Lead or Co-Registrant Seeking Support? REACHLaw Türkiye offers Only Representative and comprehensive compliance services for KKDIK. For assistance, contact us at sales@reachlaw.fi.

Procedures and Principles document published by the MoEUCC can be found here: Kimyasalların Kayıt Sürecine İlişkin Usul ve Esaslar Belirlendi. | Kimyasallar Yardım Masası