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KKDIK CMR Articles and 31 December 2026 Full Registration
In the KKDIK registration calendar, 31 December 2026 is not only for substances of 1,000 tons and above per year; It is also the full registration deadline for CMR substances that meet certain thresholds. In other words, even a company operating in low tonnage can enter the earliest registration wave if its article is CMR 1A or 1B.
What is CMR?
CMR is the abbreviation for three hazard classes:
- C — Carcinogenic (SEA Regulation Annex-1, section 3.6)
- M — Germ cell mutagenicity (section 3.5)
- R — Toxic to the reproductive system (section 3.7)
The decisive factors in terms of KKDIK are categories 1A and 1B. Category 2 substances are not included in this scope. The same three classes are also the first three clauses of the substance of high concern criteria in Article 47 of KKDIK — meaning that a CMR 1A/1B substance may also be included in the Annex-14 authorization list in the future.
How many CMR items are in Türkiye's inventory?
We counted on the 6,212-item open data set that we extracted from the harmonized classification list in the annex of KKDIK:
| Harmfulness | Number of items |
|---|---|
| CMR 1A/1B — total (singular item) | 1.072 |
| Carcinogenic 1B | 810 |
| Mutagen 1B | 420 |
| Carcinogenic 1A | 171 |
| Reproductive toxicity 1B | 162 |
| Toxic to the reproductive system 1A | 21 |
The sum of the subrows is greater than 1.072 because an item can be in more than one class. For example, benzene is both Carcinogen 1A and Mutagen 1B.
The CMR 1A/1B ratio in the entire inventory is approximately 17%. Together with Aquatic hazardous substances, the total number of substances subject to December 31, 2026 is 1,950 — 31.4% of the inventory. Detail: Full registration 31 December 2026.
Examples of CMR materials commonly seen in industry
| Article | CAS | Classification in the annex of KKDIK |
|---|---|---|
| Benzene | 71-43-2 | Carc. 1A, Muta. 1B |
| Vinyl chloride | 75-01-4 | Carc. 1A |
| Chromium (VI) trioxide | 1333-82-0 | Kans. 1A, Muta. 1B, Rep. Fog. Full. |
| Cadmium | 7440-43-9 | Carc. 1B |
Caution: Not exactly the same as the EU CLP classification
This is the most common mistake. Companies make a decision by looking at the classification in the supplier's EU safety data sheet. The harmonized list in the KKDIK annex and the EU CLP Annex-6 list are not the same in every article.
Concrete example: formaldehyde (CAS 50-00-0) is included in the KKDIK annex as Carcinogenic category 2; In EU CLP, it is Carcinogen 1B. In other words, this article, which is considered CMR 1B on the EU side, is evaluated differently because it is category 2 in terms of KKDIK's 31 December 2026 CMR threshold.
Rule: verify classification from KKDIK annex, do not assume from EU source. If you are implementing two pieces of legislation together, see our KKDIK and EU REACH two-way compliance page.
Second warning: not being on the list is not exempt
Of the 6,212 substances, 3,939 have harmonised hazard statements (H codes), while 2,273 do not. A blank entry does not mean a substance is harmless; it means its classification has not been harmonised in this list.
In this case, the responsibility for classification belongs to you: you classify it according to SEA Regulation criteria with your own data and if the result is CMR 1A/1B, the liability of 31 December 2026 arises. See SEA classification approach.
What should a company with a CMR article do?
- Scan your inventory by CAS. Match by CAS number, not product name — the same item may come with different trade names.
- Verify harmonized classification from KKDIK annex. Look at the annex itself, not the supplier SDS.
- If there is no harmonization record, classify it yourself and document the justification.
- Monitor your tonnage annually. The CMR threshold is evaluated together with the tonnage — see annual tonnage tracking.
- Start full log file early. Data requirement in CMR items is heavy; chemical safety report and exposure scenarios require time.
- Take into account Annex-14 risk. CMR 1A/1B is the criteria for candidacy for the authorization list. What does
ONAY Mühendislik do?
We match your substance inventory with the KKDIK harmonized list on a CAS basis and report CMR 1A/1B issues and 31 December 2026 liability; For substances that do not have a harmonized registration, we make the CLP classification and prepare the full registration dossier and chemical safety report. Contact.
Data source: Open dataset of 6,212 items derived from the KKDIK harmonized classification list (CC BY 4.0). The dataset is published with the permanent address: DOI 10.5281/zenodo.22247796 · kkdik.ai dataset page. Classification basis: KKDIK Regulation and CLP Regulation Annex-1. Calendar basis: Official Gazette 23.12.2023 / 32408 amendment regulation. Related pages: record calendar · hazard classes and H phrases.