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On March 4, 2026, the Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) issued an official notice updating the compliance requirements for the Registration, Evaluation, Authorization and Restriction of Chemicals (KKDIK). The MoEUCC announced that temporary registration is now mandatory for all applicable chemical substances, regardless of Lead Registrant (LR) availability. To facilitate this, the MoEUCC has introduced a new "individual" temporary registration pathway in the Chemical Registration System (KKS), allowing companies to complete their temporary registrations independently by September 30, 2026, even in cases where industry coordination has stalled or an LR has not been appointed.
Resolving SIEF Bottlenecks via Individual Submissions
Previously, many companies faced compliance bottlenecks because their respective Substance Information Exchange Forums (SIEFs) failed to elect a Lead Registrant, leaving co-registrants in a passive state. Following consultations with the Chemicals Advisory Group in late 2025 and early 2026, the MoEUCC resolved this deadlock by eliminating the strict dependency on an LR for temporary registrations.
Under the new regulatory framework, companies can no longer cite the absence of an LR or SIEF coordination difficulties as a valid reason for delaying registration. The MoEUCC has updated the KKS portal to accept standalone submissions. When utilizing this individual temporary registration pathway, registrants are required to clearly state their justification for submitting individually within the system.
Critical Regulatory Deadlines
The official communication establishes strict deadlines for different actors within the supply chain to ensure regulatory compliance progresses smoothly:
March 31, 2026: Lead Registrants must complete their submissions for temporary registration or formal registration. This step is a prerequisite for other SIEF members to proceed with the compliance work.
September 30, 2026: All joint submission members and companies utilizing the individual temporary registration pathway must complete their submissions.
Compliance Action Guide
Industry professionals must assess the current status of their substance's Lead Registrant to determine the correct compliance route. The required actions are outlined in the table below:
Lead Registrant (LR) Status | Required Action for Companies | Applicable Deadline |
|---|---|---|
LR has completed the submission for temporary registration or formal registration | Join the temporary registration or formal registration as a joint submission member. | September 30, 2026 |
No LR appointed / LR is inactive | Submit an individual temporary registration with a stated justification via the KKS portal. | September 30, 2026 |
Strategic Considerations for Industry Professionals
While the individual submission pathway provides a critical safety net to meet the September 2026 deadline, assuming the Lead Registrant role remains a strategically advantageous compliance route for substances currently lacking an active LR. Applying for the LR status allows a company to maintain full control over the registration timeline and compliance certainty. Furthermore, acting as the LR establishes a primary position for future data-sharing negotiations and the eventual formal registration processes, providing a more robust long-term regulatory footing compared to the individual temporary submission fallback.
Companies are advised to immediately verify the LR status of their portfolios and either prompt existing LRs to act before the March 31 deadline or initiate their own individual/LR registration procedures to guarantee compliance.
