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In January 2025, the Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) informed the industry about the KKDIK Enforcement Principles and Procedures (Draft) to solicit public comments. The consultation period will end on February 24, 2025.
Highlights
This draft does not seem promising as a solution for issues encountered in KKDIK implementation, but it will still have some impact. Highlights are summarized below.
1. Pre-registration (Pre-SIEF) Deadlines
For substances that have been on the Turkish market, companies are obligated to submit pre-registration application via the chemical registration system - Kimyasal Kayıt Sistemi (KKS) before June 30, 2025.
For substances manufactured and/or imported for the first time after 30 June 2025, pre-registration should be applied for according to the stipulated timelines for different tonnage bands, more specifically:
a) Pure substances (or those contained in mixtures/articles) in volume within 100 t/y ~ 1,000 t/y: 31 December 2027 will be the deadline for pre-registration.
b) Pure substances (or those contained in mixtures/articles) in volume within 1 t/y ~ 100 t/y: 31 December 2029 will be the deadline for pre-registration.
2. Lead Registrant
The determination of the lead registrant is primarily based on volunteering. If there is no volunteer company, the MoEUCC and the Union of Chambers and Commodity Exchanges of Turkey (TOBB) will cooperate to appoint a company as the Lead Registrant among the companies with the max tonnage, the most data, and the largest company scale, in order of priority. If companies intend to place their substances on the market before 31 December 2030, a lead registrant should be appointed by at least 30 September 2025.
3. Interim Registration
Interim registration is a step between pre-registration and formal registration.
Lead registrants should complete the interim registration before 31 December 2025. Required information prescribed in Annex EK-1 of this draft should submitted to the MoEUCC, including dossier of joint submission, chemical identification, classification and labeling info, estimated quantity, use and exposure info, etc. Following the lead registrant completes the interim registration, other co-registrants should submit the member registration entries before 30 June 2026.
For companies that are not co-registrants for joint registration and intend to complete registration individually, they should complete the interim registration by submitting the required information in Annex EK-1 of this draft by 31 December 2025.
This supporting document is still in the draft stage. It has caused a lot of confusion and controversies within the industry. Some of the deadlines are set too tightly, putting pressure on companies to comply. It is recommended that companies needing to export to Turkey actively monitor the final release of this document.
Additionally, with the KKDIK registration deadline approaching, those who have already pre-registered should also keep a close eye on the registration status of their pre-registered substances and complete the registration before the corresponding deadlines to avoid impacting product exports.
The draft (in Turkish) can be accessed here.
Background
KKDIK is an acronym for Registration, Evaluation, Authorization and Restriction of Chemicals in Turkish. The KKDIK regulation (Turkey REACH) was published in June 2017 and took effect on December 23, 2017. By the official gazette dated December 23, 2023, the Turkish MoEUCC revised KKDIK regulation to gradually extend the registration deadlines based on tonnage and hazard classification (CL news). It faces issues with a slow registration process, and the number of completed registrations is discouraging. Following the KKDIK revision, studies were carried out on the enforcement principles and procedures to ensure the effective implementation of KKDIK regulation. A draft has been prepared, and the MoEUCC is currently inviting the industry to evaluate and give feedback on this draft.
