KKDİK is Türkiye’s framework for the registration, evaluation, authorisation and restriction of chemicals. It is modelled on EU REACH, with similar principles but a different timetable and implementation. This guide explains which parts apply to which companies and how.
Rule of thumb: “no data, no market”
The regulation rests on one principle: if you manufacture or import a substance in Türkiye at 1 tonne or more per year, you are responsible for generating and submitting the data demonstrating its safety. The burden of proof rests with the party placing it on the market.
Two conclusions emerge from this: the registration is given to the company, not the substance, and companies that register the same substance must share the data.
The main blocks of the Regulation and your part
| Editing area | What it regulates | The responsibility of the company |
|---|---|---|
| Registration | Dossier obligation for substances over 1 tonne/year | Tonnage determination, technical file, presentation to KKS |
| Data sharing and shared registration | Bringing people who saved the same article together in a single file | Pre-MBDF query, MBDF, LoA |
| Information chain | Information flow in the supply chain | Turkish SDS, exposure scenario if necessary |
| Sub-user obligations | Those who do not register but use the substance | Compliance of use with the scenario, GTZ evidence file |
| Evaluation | Ministry's file and article review | Timely response to requests for information |
| Permission and restriction | Substances of very high concern, prohibited/conditional uses | Portfolio screening, SVHC tracking, alternative plan |
Most companies know the first two lines and skip the fourth line. A downstream user who is not obliged to register also has an obligation: to check whether the substance he uses falls within the usage scenario declared in the registration. For details, see our article subuser obligations.
Calendar: the real face of the regulation in practice
The Regulation came into force in 2017, but what is decisive for companies is the transition schedule:
| Liability | Deadline | Who it covers |
|---|---|---|
| Temporary registration | September 30, 2026 | 1 tonne and above per year, everyone, regardless of tonnage |
| Full registration | December 31, 2026 | over 1,000 tons/year; CMR 1A/1B (over 1 ton); Aquatic Acute 1 / Chronic 1 (over 100 tons) |
| Full registration | December 31, 2028 | 100 – 1,000 tons/year |
| Full registration | December 31, 2030 | 1 – 100 tons/year |
The date of 30 September 2026 is the harshest line in this table: it does not discriminate tonnage and if it is missed, the substance cannot be placed on the market. You can see which line you fall into for your item in our due date and cost tool with the CAS number.
Can you opt out?
The Regulation does not cover every article in the same way. Exemption headings are defined in the annexes: certain natural substances, polymers under certain conditions, waste, limited quantities for scientific research purposes, product groups regulated by other legislation. In addition, there is no registration obligation below the annual 1 tonne threshold.
Attention: registration exemption is not an exemption from all obligations. Classification, labeling and SDS obligations remain in most cases. For coverage check, see KKDIK exemptions page.
Relationship to REACH
KKDIK is the Turkish adaptation of REACH; However, your registration in the EU is not considered valid in Turkey. The REACH file you have is a data source, not a shortcut. The presentation is made in Turkey, via KKS, with Turkish documents. For comparison, the KKDIK and REACH difference page is helpful, and for the use of existing EU data, the Use of REACH data in KKDIK page is helpful.
Provision for incompatibility
Failure to register, submit an incomplete file, or fail to fulfill the SDS obligation will result in administrative fines and withdrawal from the market. For the current sanction framework, you can check our KKDIK administrative fines page.
Frequently asked questions
What does KKDIK stand for?
Registration, Evaluation, Authorization and Restriction of Chemicals.
Whom does the Regulation bind?
Companies that manufacture, import, place on the market and use chemicals in Turkey as downstream users — with different obligations depending on their role.
Can a foreign manufacturer register directly?
No. Registration is made by a legal entity established in Turkey: the importer or the appointed only representative.
I am importing a mixture, does the regulation cover me?
Liability arises not to the mixture but to the substances in it. Tonnage and scope are evaluated separately for each component.
Together we can figure out which obligations your portfolio falls into — contact us.
Official full text of the regulation: KKDIK Regulation - Official Gazette.
Company Liability Under the KKDIK Regulation
KKDIK Regulation links the liability to the legal entity; In group companies, each company is individually responsible for its own tonnage. In groups importing the same substance through different subsidiaries, the quantities are not combined, resulting in some subsidiaries being below the threshold. What is decisive in terms of the KKDIK Regulation is not the group turnover, but the amount of each legal entity within its own calendar year.
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