Registrars within the scope of KKDIK must complete their provisional or full registration by September 30, 2026, regardless of tonnage and whether there is a lead register. Final full registration dates are determined according to the tonnage band and hazard characteristics of the substance.
The first step is to inventory the substance and accurately calculate the annual tonnage for each substance. Then, pre-MBDF query is made, MBDF is created with the companies that register the same substance and data sharing is planned. Data gaps are closed by testing, literature or QSAR/read-across and an IUCLID technical file is prepared.
The biggest risk is being late: data collection and testing processes can take months. In accordance with the principle of 'No registration, no market', the supply of the substance whose registration has not been completed may be stopped and inspections are expected to become more frequent after September 30, 2026. ONAY Mühendislik manages the entire process from inventory analysis to IUCLID file.
Why Is There Urgency Despite the Time
Although the deadline is September 30, 2026, the workload behind the registration file requires starting well before that date. Long-term testing studies can exceed one year, including laboratory benches; access permission negotiations take weeks; Internal data collection involves multiple departments. When the calendar is set backwards, it becomes clear that the work should have already started.
First Step: Inventory and Role Determination
The first thing to do is to break down all manufactured and imported substances on a CAS basis and determine the role of the company for each substance. It is clarified at this stage whether the foreign manufacturer can appoint a sole representative; If it is appointed, the liability lies with the representative, not the importer, and this must be documented.
Second Step: Tonnage and Threshold Analysis
The calendar year total amount for each item is calculated and compared to the registration threshold. A tonnage band is determined for substances exceeding the threshold; The band directly determines the data set to be requested and the chemical safety report requirement. The calculation must be made based on the weight of the pure substance.
Step Three: Forum and Data Gap
For each item that exceeds the threshold, the relevant forum is attended and the available data is compiled. Then, the gap analysis is completed by making a comparison with the data set required by the tonnage band. This analysis is the critical output that determines both the need for testing and the scope of access permission.
Step Four: Access Permission and File
Access permission offers are requested on an item-by-item basis, and works that are not required by your own band will be excluded from the offer. Simultaneously, company-specific sections of the dossier are prepared: use descriptions, actual working conditions and exposure information. This data is collected from the field and is often incomplete in the first round.
Tracking Progress with Checkpoints
The schedule should include not only the deadline but also intermediate milestones: completion of the gap analysis, signing of the access grant agreement, placement of test orders, and passing of the dossier through technical control. Prompt calculation of the impact when a milestone is missed is the only way to compensate.
KKDIK Monthly Control Rhythm before 30 September 2026
It is recommended that progress be monitored monthly until the KKDIK 30 September 2026 target. The following three questions must be answered every month: which items were closed in the gap analysis, which access permission negotiation is at which stage, which test order was placed. A missed month in the KKDIK September 30, 2026 calendar often turns into an irreparable delay.
September 30, 2026 Provisional Registration or Full Registration?
The 30 September 2026 deadline means that the registrar must have made a temporary registration or full registration for the item by that day. Temporary registration; It is based on correct entry of basic declarations such as company information, substance identity (CAS/EC), supply chain role and tonnage into the KKS. Full registration requires data sharing, common registration structure and technical file; The final date varies depending on the tonnage band and harmfulness characteristics.
Temporary registration does not replace full registration; However, there is a risk that the substance will remain on the market if it is not temporarily registered on September 30, 2026. The order of priority in recent weeks is:
- Verify provisional registration status for each substance on an article-by-item basis against your own record or your supplier's record: supplier provisional registration checklist.
- If you are going to act separately from the joint submission, review the individual provisional registration 2026 guide.
- Plan the transition from temporary registration to full registration according to the temporary registration and full registration difference page.
- Collect your evidence for the possible audit according to the September 30, 2026 audit preparation list.
Related pages
Contact ONAY Mühendislik for your process.
Official full text of the regulation: KKDIK Regulation - Official Gazette.