In January 2025, the Turkish Ministry of Environment, Urbanization, and Climate Change (MoEUCC) released the draft KKDIK Enforcement Principles and Procedures for public consultation. The consultation period will close on February 24, 2025.

Key Highlights

While the draft does not provide a clear solution to existing challenges in KKDIK implementation, it introduces notable regulatory requirements that will impact businesses. The key points are summarized below:

1. Pre-registration (Pre-SIEF) Deadlines

• Companies must submit pre-registration applications via the Kimyasal Kayıt Sistemi (KKS) for substances already on the Turkish market but not yet registered by June 30, 2025.

• For substances manufactured or imported for the first time after June 30, 2025, pre-registration deadlines are set based on tonnage bands:

  • 100–1,000 t/y: Deadline December 31, 2027

  • 1–100 t/y: Deadline December 31, 2029

2. Lead Registrant Selection

• The lead registrant will be determined primarily on a voluntary basis.

• If no company volunteers, MoEUCC and the Union of Chambers and Commodity Exchanges of Turkey (TOBB) will appoint a lead registrant based on:

  • Highest tonnage

  • Most available data

  • Largest company scale

• If companies intend to place substances on the market before December 31, 2030, a lead registrant must be appointed by September 30, 2025.

3. Interim Registration

Interim registration serves as a bridge between pre-registration and full registration.

• Lead registrants must complete interim registration by December 31, 2025, submitting required data (Annex EK-1) to MoEUCC, including:

  • Joint submission dossier

  • Chemical identification

  • Classification & labeling

  • Estimated quantity

  • Use and exposure information

• Co-registrants must submit their member registration entries by June 30, 2026.

• Individual registrants (not participating in joint registration) must also complete interim registration by December 31, 2025.

Industry Concerns & Recommendations

The draft has sparked confusion and controversy within the industry, mainly due to tight deadlines and increased compliance pressure. Businesses exporting to Turkey should closely monitor the finalization of this regulation.

Additionally, as the KKDIK registration deadline approaches, companies that have pre-registered must track the registration status of their substances and ensure timely compliance to prevent disruptions to product exports.

Background

KKDIK stands for Registration, Evaluation, Authorization, and Restriction of Chemicals in Turkish. Often referred to as Turkey REACH, the regulation was first published in June 2017 and became effective on December 23, 2017.

On December 23, 2023, MoEUCC revised KKDIK to extend registration deadlines based on tonnage and hazard classification. However, slow progress in registrations has led to the development of enforcement principles and procedures to improve implementation. The current draft is open for feedback, and industry stakeholders are encouraged to participate in the consultation process.

“Stay ahead in sustainability compliance with Global PCCS,—where expert insights meet the latest regulations. Unlock a future where compliance fuels sustainability, helping your business thrive in a greener, well-regulated world. For more information, contact us at info@globalpccs.com.“