The first question to ask before importing a substance to Turkey or placing it on the market is: is this substance within the scope of KKDIK, is it registered, what is my obligation? The answer cannot be read from a single list; It comes from the combination of three separate controls. Below we explain this check step by step, starting from the CAS number.
Let's get the concept straight first: “registered substance list” is misleading
As in EU REACH, there is no single publicly available inventory in KKDIK that says "these substances are registered, the rest are not". Registration is given to each company separately, not to substance. If 40 companies import the same substance, 40 separate registration obligations arise. Your supplier's registration does not replace your own registration — the only exception is if a only representative appointed by the overseas manufacturer undertakes the registration on behalf of the importer.
Therefore, the correct form of the question “is this item registered” is: is this item in scope, what role and what tonnage am I in, what is the deadline for me?
Step 1 — Secure the item with its ID
The trade name is useless. Obtain CAS and EC number from section 3 of the Safety Data Sheet. If you are buying a mixture, each component is looked at separately; The registration obligation arises not to the mixture but to the substances contained therein.
Frequent error: hydrate, salt or form of different purity of the same substance carrying separate CAS numbers. If the ID is wrong, all subsequent steps will be wrong. For the weight of the substance ID in the log file, see our substance identification (SID) article.
Step 2 — Scope and exemption check
Not every item requires registration. There are exempt groups in the annexes of the regulation: some natural substances, polymers under certain conditions, materials with waste status, limited quantities for scientific research purposes, some products regulated by other legislation. Additionally, quantities below the 1 tonne threshold per year do not result in registration obligations — but this does not remove your SDS and classification obligations.
For details, you can refer to KKDIK exemptions and status of polymers pages.
Step 3 — Calculate tonnage band correctly
Tonnage is collected on a per legal entity, per item, calendar year basis. If you buy the same item from three different suppliers, all three are added together. When the band changes, both the deadline and the fee change.
| Tonnage band (annual) | Registration deadline |
|---|---|
| 1,000 tons and above | December 31, 2026 |
| CMR Category 1A/1B (over 1 tonne) | December 31, 2026 |
| Aquatic Acute 1 / Aquatic Chronic 1 (over 100 tons) | December 31, 2026 |
| 100 – 1,000 tons | December 31, 2028 |
| 1 – 100 tons | December 31, 2030 |
There is only one other date above this calendar, independent of tonnage: 30 September 2026 provisional registration deadline. It covers everyone who manufactures/imports 1 ton or more per year.
Step 4 — Check the hazard class of the substance
It's not just tonnage that determines the deadline. The CMR 1A/1B or aquatic toxicity classification moves the substance into the 2026 tail, even at low tonnage. You can query the classification of your substance and its associated deadline via our registration cost and deadline tool with its CAS number; The tool operates from an open dataset of 6,212 items.
You can also use kkdik.ai CAS directory for item-based detailed records.
Step 5 — See who posted the same item as the pre-MBDF query
Once you have determined that you are in scope, a pre-MBDF query via KKS will show you who is in the registration process for the same item. Joint registration is essential; This step paves the way for both fee reduction and data sharing. See our pre-registration / pre-MBDF page for the process.
Three documents you will request from the supplier
- Current SDS — Turkish, KKDIK format, 16 chapters
- Registration or temporary registration number — if available, it must be specified in the relevant section of the SDS
- Exclusive representative appointment — if you are purchasing from a foreign manufacturer, the appointment letter and confirmation that the representative covers you
The third point is the most frequently overlooked point: if a sole representative is appointed, the importer becomes a "downstream user" and the registration obligation is eliminated. If there is no appointment, the obligation lies with the importer.
Frequently asked questions
Does Turkey have a publicly available KKDIK inventory?
A clear inventory showing registered company-item matches is not published. Scope and classification information is tracked through legislative annexes and data sets.
If my supplier has registered, should I too?
If you are purchasing from a domestic supplier, generally no, you will be a downstream user. Yes, if you are importing and a sole representative has not been appointed.
I gain 800 kg per year, is registration required?
No recording required below 1 tone threshold; SDS, classification and labeling obligations continue. Track tonnage throughout the year — if the threshold is exceeded, liability arises immediately.
If you would like to evaluate the scope and tonnage together, contact us.
Who Determines Whether It Is Within the Scope of KKDIK?
It is not the institution that determines whether a substance is within the scope of KKDIK, but the company that puts that substance on the market and is obliged to document this assessment. If an out-of-scope decision is made as a result of the query, it should be recorded in writing which exemption provision is the basis. The most common mistake made in articles that are not considered to be within the scope of KKDIK is that the source of the exemption is not written at all.
Scope and record queries are executed via KKS.