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What are the sanctions if I do not register with KKDIK?
Failure to fulfill KKDIK obligations will result in administrative and commercial consequences. It is against the legislation to produce or import 1 ton or more of substances per year without registration; In accordance with the principle of "no registration on the market if there is no registration", the supply of unregistered substances to the market can be stopped, administrative sanctions can be applied during inspections and precautions can be taken for the products. Additionally, missing or incorrect files lead to additional data requests and delays in the evaluation process. Since inspections are expected to become more frequent after September 30, 2026, timely completion of obligations is critical for your commercial continuity.
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For questions, contact ONAY Mühendislik.
The two pillars of the sanction
The consequences of failure to comply with the registration obligation are divided into two. The first is an administrative fine and the amount varies depending on the nature of the violation. The second, and more serious for most companies, is the suspension of the supply of the substance to the market. Even if production continues, sales cannot be made.
What is required in the audit?
- Substance inventory and annual tonnage records
- Evidence of registration or pre-registration
- Exclusive representative appointment documents
- Examples of safety data sheets and labels
- Subuser scenario verification records
What to do when you notice the deficiency?
Waiting makes the situation worse. First, take inventory and determine which items are unregistered. Then start the pre-registration and forum process immediately. Initiating the process can be considered as good will and compliance efforts in the audit.
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Official full text of the regulation: KKDIK Regulation - Official Gazette.
Who is sanctioned?
The responsibility lies with the legal entity that places the substance on the Turkish market. Citing a manufacturer abroad does not provide a defence. Therefore, registration evidence, tonnage records and forum correspondence should be kept in a single evidence file and be available at once when an audit is requested.
Other KKDIK Questions
- What is the difference between KKDIK and REACH?
- How long does KKDIK registration take?
- Who should register with KKDIK?
- Is it mandatory to appoint a Only Representative?
- What is a UFI code and how to get it?
- What is PCN notification?
- What is IUCLID?
- What is KKS (Chemical Registration System)?
- Is it mandatory to prepare SDS/SDS?
- How to prepare KKDIK technical file?
- Are polymers subject to KKDIK registration?
- What documents are required for KKDIK registration?
- What is MBDF management?
- Temporary registration and full registration difference
- Leader, joint and individual registration