Home/KKDIK Full Registration: 31 December 2026 Deadline and Scope
KKDIK Full Registration: 31 December 2026 Deadline and Scope
The provisional registration deadline of September 30, 2026 is the only date on most companies' agendas. However, 31 December 2026, which comes three months later, brings a much heavier obligation: full registration. Provisional registration is a notification; A full record means a complete technical file.
Who must be fully registered on 31 December 2026?
The amendment regulation (OG 23.12.2023 / 32408) binds two groups to this date:
- Substances manufactured or imported 1,000 tons or more per year
- CMR (carcinogenic, mutagenic, toxic to the reproductive system) and harmful to the aquatic environment substances that meet the relevant thresholds
In the second group, the thresholds are different: 1 tonne and above per year for CMR Category 1A/1B; For Aquatic Acute 1 and/or Aquatic Chronic 1, 100 tons and above are evaluated annually. The hazard class alone does not determine the registration date.
Full recording schedule
| Date | Liability |
|---|---|
| September 30, 2026 | Completion of temporary records regardless of tonnage |
| 31 December 2026 | full registration for CMR and aquatic harmful substances meeting thresholds of 1,000 tonnes per year and above + |
| December 31, 2028 | Full registration for substances in the range 100–1,000 tonnes per year |
| December 31, 2030 | Full registration for substances in the range 1–100 tonnes per year |
See the KKDIK registration calendar page for the full schedule and provisional registration details.
Hazard classes in open data set
We counted CMR 1A/1B and aquatic hazard classifications in our open dataset of 6,212 substances derived from the KKDİK harmonised classification list. These classification counts do not include company-level tonnage, so they are not counts of companies or registrations subject to a particular deadline:
| Group | Number of items | Ratio to inventory |
|---|---|---|
| CMR 1A/1B | 1.072 | %17,3 |
| Aquatic Acute 1 / Chronic 1 | 1.094 | %17,6 |
| Both (conflict) | 216 | %3,5 |
| Substance contained in at least one of two hazard groups | 1.950 | %31,4 |
This ratio indicates the hazard classes in the open data set examined; It is not the rate of all substances or 2026 registration obligations in the Turkish market. For the registration date, annual tonnage, classification and exemptions should be evaluated together on a company basis. Base: Amendment regulation dated 23 December 2023, article 7.
Difference between temporary registration and full registration
| Temporary registration | Full registration | |
|---|---|---|
| Purpose | Creation of country inventory | Documentation of safe use of the substance |
| Content | Substance and company information, tonnage declaration | Full technical file + KGR if required |
| Data requirement | Barely any | Annex-7 to Annex-10 according to tonnage band |
| MBDF | Pre-MBDF query | Joint registrar, lead registrar, access letter |
| Duration | Days | Months — longer if testing is required |
Detail: temporary registration and full registration difference.
What's in the full log file?
- Substance ID — see substance identification (SID)
- Data set by tonnage band — Annex-7 to Annex-10; see tonnage band data requirements
- Chemical safety report — For 10 tons and above; see KGR
- Exposure scenarios and risk management measures
- File in IUCLID format — see What is IUCLID
- Joint registration documents — letter of access (LoA), MBDF memorandum
Roadmap from today to December 31, 2026
- Remove inventory by CAS. CAS, not trade name. The same substance may come with different names.
- Verify hazard profile from KKDIK annex. Do not assume from EU CLP; No two lists are the same on every item.
- Finalize tonnage on an annual basis. See. annual tonnage tracking.
- Query Pre-MBDF and contact those who have posted the same item — see pre-MBDF query steps.
- Extract data gap analysis. Plan for missing tests and deadlines today.
- Decide whether to be a lead registrar or a member. See. leader and member recorder difference.
- If you are a foreign manufacturer, appoint a sole representative. See. sole representation services.
What happens if you miss it?
The basic principle of KKDIK does not change: it is not possible to manufacture or place the substance on the market without fulfilling the registration obligation. Production and sales will stop for the substance that is not fully registered after the deadline; Additionally, administrative sanctions are applied. See administrative fines and sanction for not registering.
ONAY Mühendislik do?
We screen your inventory against the criteria for 31 December 2026 and identify each substance’s registration wave and deadline. We manage data-gap analysis, MBDF negotiations, IUCLID dossiers and chemical safety reports from start to finish. Contact us or explore our consultancy services.
Calendar basis: OG 23.12.2023 / 32408 amendment regulation. Provisional registration date: Ministry of Environment, Urbanization and Climate Change Chemicals Help Desk announcement. Number of items: Open data set 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.