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Turkey REACH (KKDIK)

Sundae Ji Last updated on: Sep 26, 2025

1 Overview

The Turkish Ministry of Environment, Urbanisation and Climate Change (MoEUCC) introduced its REACH-like regulation on June 23, 2017, namely By-law on Registration, Evaluation, Authorization and Restriction of Chemicals, also known as ‘Turkey REACH’. The acronym for this regulation in Turkish is ‘KKDIK’.

By the official gazette dated December 23, 2023, the MoEUCC issues the amendments to the KKDIK Regulation (Turkey REACH) to gradually extend the registration deadlines based on tonnage and hazard classification. However, the implementation of Turkey REACH still faced issues with a slow registration process, and the number of completed registrations is discouraging.

Therefore, in recent years, the MoEUCC has engaged in extensive consultation with industry stakeholders on how to ensure the effective implementation of Turkey REACH. On August 12, 2025, the MoEUCC issued the KKDIK Enforcement Principles and Procedures to facilitate corporate actions and address challenges such as appointment of Lead Registrant and registration issues through phased policies.

2 Exemptions from KKDIK

KKDIK (Turkey REACH) does not apply to the following:

  • Radioactive substances

  • Substances subject to customs supervision

  • Substances for use in national defense

  • Wastes

  • Non-isolated intermediates

  • Carriage of hazardous substances by rail, road, inland waterway, sea, or air

3 KKDIK Registration

Under Turkey RAECH, chemical substances, on their own or in mixtures or intended to be released in articles, manufactured in or imported to Turkey in quantities equal to or more than 1 t/y must be registered with the MoEUCC.

KKDIK registration includes two stages, namely Pre-registration and Registration. Registrants include Turkish manufacturers and importers of chemical substances, mixtures, articles, and the only representative (OR) appointed by overseas manufacturers/suppliers.

Interim Registration, a new compliance pathway between pre-registration and registration, is introduced in the KKDIK Enforcement Principles and Procedures to advance the registration process. It allows potential registrants, who are unable to submit complete registration dossiers by the corresponding registration deadlines, to submit incomplete dossiers.

Specific exemptions, dossier requirements, registration deadlines, and lead registrant appointment issues are detailed in the ChemLinked analysis - A Comprehensive Look at Turkey REACH: Key Obligations and Latest Updates.

4. Other Obligations under KKDIK

Except for registration, KKDIK (Turkey REACH) also imposes obligations of evaluation, authorization, restriction and SDS compliance.

Evaluation

Evaluation under KKDIK will be conducted by the MoEUCC, covering the following three areas:

  1. Examination of testing proposal

  2.  Compliance check of registrations

  3. Substance evaluation

After evaluation, the MoEUCC will make decisions on:

  • Whether or not more information or evaluation is required

  • Whether or not the substance will be included in the Authorization List or the Restriction List

Authorization

Substances that are identified as substances of high concern (SVHC) will be included in the Candidate List. Based on the gathered opinions from stakeholders, especially the uses that should be exempt from authorization requirements, the MoEUCC will publish the inclusion in the Authorization List (Annex XIV) after assessment.

For substances in the Authorization List, they cannot be manufactured, imported or used unless any authorization has been granted.

Restriction

So far, a total of 66 types or groups of substances have been included in the Restriction List (Annex XVII) with effective dates for corresponding restriction measures.

A substance on its own, in a mixture, or in an article, for which Annex XVII contains a restriction, shall not be manufactured, placed on the market, or used unless it complies with the conditions of that restriction.

SDS Compliance

The Turkish SDS regulation was replaced by Annex II of KKDIK Regulation on December 31, 2023. Suppliers of a substance or a mixture meeting certain conditions shall provide a safety data sheet (SDS) complied in accordance with Annex II in Turkish. The SDS shall be prepared by a local certified chemical assessment specialist.

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