The Blog

Today, 30 September 2026, is the final day for companies to submit provisional registrations for their substances to the Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC).

From tomorrow – 1 October 2026 – the focus moves to the next phase of compliance. Companies placing KKDIK-regulated substances on the Turkish market should assess their provisional registration status and address any outstanding obligations, while preparing for the next major milestone: the 31 December 2026 full registration deadline for the substances concerned.

For manufacturers and importers, provisional registration should therefore be viewed as a starting point, not the end of the KKDIK compliance process. The key considerations now are whether each substance is appropriately covered by a valid provisional or full registration and whether the company has a clear and timely pathway toward full registration.

From Deadline-Driven Compliance to Market Readiness

The Turkish authorities introduced the provisional registration requirements to strengthen Türkiye’s national chemicals inventory and provide the Ministry with greater visibility over substances placed on the Turkish market.

From October 2026 onwards, companies should expect a more evidence-based compliance environment. Customers, business partners and, potentially, the authorities may increasingly ask companies to demonstrate that the substances they place on the Turkish market are appropriately addressed under KKDIK.

For substances that were not provisionally or fully registered by 30 September 2026, continued market access will require the applicable provisional or full registration requirements to have been fulfilled before they are placed on the Turkish market.

What About New Substances?

The provisional registration procedure will not disappear after today, 30 September 2026. It remains relevant for so-called “new substances” – those manufactured in or imported into Türkiye for the first time after the September 2026 provisional registration deadline, where KKDIK registration requirements apply.

Companies introducing new substances should therefore assess the applicable registration route and deadline before placing them on the Turkish market. Where the applicable full registration deadline has already passed for these new substances, full registration must be completed before placing the substance on the market in Türkiye. In such cases, provisional registration is not required; full registration is required instead.

The 31 December 2026 Deadline: From Planning to Execution

For substances subject to the first full registration deadline of 31 December 2026, companies now have limited time to move from provisional registration to a complete and robust registration strategy.

Key areas for companies to verify include:

• substance identity and composition;
• analytical and supporting data;
• applicable tonnage band;
• classification and labelling;
• identified uses and exposure information;
• data access and data-sharing arrangements;
• lead registrant and joint submission requirements; and
• Only Representative arrangements, where applicable.

SDSs and other supply-chain communications should also be reviewed to ensure consistency with the registration position.

An important point: Companies that have already submitted a complete full registration dossier covering the applicable annual volume and have received a full registration number for their 2026 registered substances are already KKDIK compliant. They should, however, ensure that their dossiers continue to be kept up to date after the full registration deadline, as required under the KKDIK Regulation.

2026 KKDIK Registrants: What If Some Data Is Still Missing?

The preferred approach should always be to complete the registration dossier by the deadline applicable to the substance wherever reasonably possible.

However, companies may face situations where certain information cannot be obtained on time despite having taken appropriate steps to do so. In such cases, the MoEUCC has indicated that it will be possible to request, with appropriate justification, an extension of up to two years from the applicable registration deadline for the provision of the missing information, effectively postponing the submission of the full registration dossier. This procedure is expected to mostly affect lead registrants and individual registrants (where permitted), but could potentially also be used by co-registrants that do not agree with the data and cost sharing of a joint submission.

The final mechanism for requesting the extension, including how it will work in practice and interact with the registration deadlines, is expected to be determined in the coming weeks. REACHLaw is following developments and will provide further details as they become available from the MoEUCC.

What 2026 KKDIK Registrants Should Prioritise Now

With the December 2026 deadline approaching, companies should focus on the following practical actions:

• Map your substance portfolio: identify all substances manufactured in or imported into Türkiye and determine which require full registration.
• Verify KKS status: confirm in the Chemical Registration System (Kimyasal Kayıt Sistemi – KKS) whether each substance has at least a valid provisional registration.
• Identify the registration route: clarify data requirements and the submission pathway for each substance.
• Check supply-chain coverage: review Turkish importers, Only Representative arrangements and downstream responsibilities.
• Confirm lead registrant status: check whether a lead registrant has been appointed for your substance and whether the lead registrant dossier has been submitted to allow joint submission.
• Establish an execution plan: close data gaps, secure data access, finalise technical documentation and set realistic submission milestones.

KKDIK Compliance Is Now About Readiness

The next phase of KKDIK compliance will favour companies that are prepared before questions are asked. A clear view of the substance portfolio, KKS status, data position, supply-chain responsibilities and registration strategy can reduce regulatory uncertainty and help protect continued access to the Turkish market.

The message from tomorrow – 1 October 2026 – is simple: provisional registration was the starting point. Full registration readiness is the priority now.

Need Support with KKDIK Registration?

REACHLaw Türkiye supports companies with KKDIK registration strategy, Only Representative services, dossier preparation and submission, provisional registration assessments, supply-chain reviews, post-submission updates and more.

Contact us at sales@reachlaw.fi.