KKDIK (Turkey REACH) Frequently Asked Questions

Questions on the Procedures and Principles Regarding the Implementation of the KKDIK Regulation

The KKDIK Procedures and Principles, published on August 12, 2025, introduced significant changes to the KKDIK process. Our team has compiled frequently asked questions on the subject:

1. When were the procedures and principles for the implementation of the KKDIK Regulation published?
   

   The procedures and principles for the implementation of the KKDIK Regulation were published on 12 August 2025 by the Ministry of Environment, Urbanisation and Climate Change of Türkiye.

2. What is a temporary registration?
   

   A temporary registration is the process by which a lead registrant or individual registrant who cannot yet fulfil all the requirements for full registration submits the basic data (listed in Annex-1 of the Procedures and Principles) to the Ministry by 31 March 2026.

3. What is the timeline for temporary registration for lead registrants?
   

   The lead registrant may submit its registration dossier to the Ministry via the KKS system and complete its temporary registration by 31 March 2026.

4. What is the timeline for temporary registration for joint registrants when the lead has made a temporary registration?
   

   After the lead has completed the temporary registration, member companies (joint registrants) must submit their temporary registration entries via KKS by 30 September 2026.

5. What is a full registration?
   

   A full registration is the final registration dossier submitted to the Ministry, which includes all information requirements (test data, use information, etc.) depending on the tonnage band, as specified in the KKDIK Regulation.

6. What is the timeline for full registration?
   

   For full registrations by joint members whose lead registrant has submitted the full dossier by 31 March 2026, the deadlines specified in the Provisional Article 2 of the Regulation apply.

   In general:

   • 31/12/2026 → ≥1000 tonnes/year and CMR/very toxic substances
   • 31/12/2028 → 100–1000 tonnes/year
   • 31/12/2030 → 1–100 tonnes/year
     
     
7. What are the differences between temporary and full registration?
   

   Temporary registration is a process that allows companies to remain on the market while gaining time to prepare a full registration, whereas full registration fulfils the final registration obligation under the KKDIK Regulation. Moreover, the content of the registration dossiers differs significantly. The deadlines also differ: there is a single deadline for temporary registration, while for full registration, deadlines vary by tonnage band between 2026 and 2030.

8. How is the lead registrant selected?
   

   The selection of the lead registrant is based on voluntariness. A candidate firm expresses its intention to act as lead registrant, providing justification, and notifies all SIEF members through KKS. All necessary communications are conducted through this system. Following the submission of the lead candidate’s request, all SIEF members must communicate their positive or negative opinions, with justifications, to the candidate within 30 days. If the lead candidate is accepted by a simple majority of SIEF members, it is designated as the lead registrant. If the candidate is not approved by a simple majority, the candidate informs all SIEF members of the situation and withdraws from candidacy. In that case, the process for selecting a new lead among SIEF members begins anew.
   
   If no voluntary candidate comes forward, the Ministry may designate a lead registrant, taking into account criteria such as tonnage, availability of data, and company size, and after consulting the Union of Chambers and Commodity Exchanges of Türkiye (TOBB).

9. What is the timeframe for the selection of the lead registrant?
   
   • For substances already on the market before 12 August 2025 (the publication date of the Procedures and Principles):
     The lead registrant must be determined by 31 December 2025.
   • For substances to be placed on the market for the first time after 12 August 2025:
     The lead registrant must be determined within 6 months following the date of first placement on the market.
   
   
10. What happens if a lead registrant is not selected?
    

    If no lead registrant is selected among SIEF members, the process is restarted.
    If no result is achieved again, the Ministry may appoint a lead registrant after consulting TOBB.

11. Can the lead registrant be changed?
    

    If the lead registrant can no longer continue its role, the lead company must inform all current SIEF members and submit a written request to the Ministry with the necessary information and documents.
    Following the Ministry’s evaluation, the system will allow the election of a new lead registrant.
    The current lead is obliged to transfer all relevant information and documents to the new lead registrant within 30 days after the Ministry’s written approval, in accordance with the data-sharing rights and the confidentiality and data protection principles set out in the Regulation.

You can benefit from our KKDIK Compliance Service to get detailed information and support about the KKDIK process.