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Last Friday, the Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) announced a major step toward establishing Türkiye’s national chemical inventory.

Under this initiative, all companies placing substances on the Turkish market that fall within the scope of KKDIK must obtain by 30 September 2026:

• A full registration number, or
• A provisional registration number

This obligation applies regardless of the substance’s tonnage band or whether a lead registrant has been appointed.

Who Is Affected

The requirement applies to all companies manufacturing, formulating, or importing chemical substances in Türkiye that are subject to KKDIK registration.

At minimum, companies must complete a provisional registration (joint or individual) by September 2026 deadline, even if the substance’s official registration deadline is later (2026, 2028, or 2030).

Provisional Registration Pathways

Scenario 1: Provisional or full Joint Registration (Lead Registrant Appointed)

Where a lead registrant has already been appointed, companies may participate in a joint registration.

In this case, co-registrants must submit their joint registration through the lead registrant by the September 2026 deadline. Based on the submitted joint dossier, the MoEUCC will issue either a full registration number or a provisional registration number.

If a company submits an individual provisional registration despite an existing lead registrant, it must provide justification in the dossier (e.g., disproportionate cost sharing, confidentiality concerns, or disagreement with the joint submission).

Companies receiving provisional registration numbers must still submit a complete registration dossier by the applicable deadline (2026, 2028, or 2030), depending on the substance’s tonnage band and classification.

Scenario 2: Individual Provisional registration (No Lead Registrant)

If no lead registrant has been appointed, companies must submit an individual provisional registration through the Chemical Registration System (KKS) by 30 September 2026.

The submission must include the information specified in Annex I of the 2025 KKDIK Procedures and Principles, such as:

1. Substance Identification (KKS Section 1.1)
   1.1 Substance Composition (KKS Section 1.2)
   1.2 Analytical Information (KKS Section 1.4)
   1.3 Suppliers: In this section, companies shall enter the names of their own downstream users and keep this information up to date. This update is not subject to a fee. (KKS Section 1.7)
   1.4 Joint Submission (KKS Section 1.5)
2. Globally Harmonised System (KKS Section 2.1)
3. Manufacturing, Use, Exposure Information (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)
4. Physicochemical Properties (KKS Section 4)
5. Guidance on Safe Use (KKS Section 11)

Companies receiving an individual provisional registration number must later submit a full registration dossier by the relevant regulatory deadline (2026, 2028, or 2030).

Important!

All submissions must be prepared in Turkish and validated by a certified Chemical Assessment Specialist (KDU).

Missing Data to Fulfill Annex I requirements? Submission Is Still Possible

If certain Annex I information is not available before the September deadline, companies may still submit a provisional registration for their substance(s) with documented justification in KKS. Missing information can be provided later, up to the applicable full registration deadline(s) (2026, 2028, or 2030).

What Happens After the 30th of September 2026

Following the deadline, the MoEUCC will begin auditing provisional and full registrations.

Key implications include:

• Companies intending to manufacture or import new substances after the September deadline must obtain provisional or full registration before market placement.
• If a company cannot join a joint submission (e.g., due to cost-sharing issues, lack of a lead registrant, or confidentiality concerns), individual provisional registration remains mandatory.
• Where data gaps exist in full registration dossiers, the Ministry may grant a two-year extension to complete the required information.

Only Six Months Remaining – Act Now

With the 30 September 2026 deadline approaching, companies should immediately:

• Screen their chemical portfolio to identify substances within KKDIK scope
• Ensure communication upstream and downstream in the supply chain
• Submit joint or individual provisional registration, per substance, per legal entity via KKS by September deadline
• Are you a formulator? Confirm suppliers’ full/provisional registration intentions, if you are not planning to register the substances contained in your mixtures that are placed on the Turkish market
• Verify Only Representative responsibilities if relying on an OR to register imported substances

Need Expert Support?

KKDIK compliance requires technical expertise, Turkish-language submissions, and certified KDU involvement.

As experienced KKDIK regulatory specialists, REACHLaw Türkiye supports Turkish and foreign companies with:

• Portfolio screening
• Data gap assessment
• Dossier preparation
• Lead Registration and co-registration
• Individual Provisional Registration
• KKS submissions
• Only Representation
• Strategic registration planning
• and more…

Contact us at sales@reachlaw.fi. Ensure your organisation remains fully KKDIK-compliant after the September 2026 deadline.

Useful links

A flowchart for how to complete Individual Provisional Registration is available at the Chemicals Help Desk via the following link: https://webdosya.csb.gov.tr/v2/cygm/2026/03/YEN-KKS-Bireysel-Ge-ici-Kayit-Akis-Semas-20260305102330…

Link to the official announcement: KİMYASAL KAYIT SÜRECİNDE İLGİLİ HUSUSLAR | Kimyasallar Yardım Masası