Can I use my REACH registration for KKDIK?

Can I use my REACH registration for KKDİK? The answer is yes, subject to conditions. As KKDİK adapts EU REACH for Türkiye, their data requirements largely overlap. However, the dossier is not automatically valid in Türkiye: a separate submission and appropriate data-use rights are required.

Same data, separate file

The work in your AB file may technically form the basis of the KKDIK file. However, the application is made through KKS and the fee is paid separately. Additionally, item similarity is reconfirmed at the forum in Turkey. In short, data is portable, but liability is not.

Usage rights issue

If your EU registration is based on data from a consortium, you may not have the right to use that data in Turkey. If the scope of your access letter is EU REACH only, a new authorization is required for KKDIK. Therefore, check the scope clause of your contract. See our letter of access (LoA) page for details.

What data can be used directly?

• Physico-chemical property studies
• Toxicological and ecotoxicological test reports
• Substance identification and analytical data
• Exposure scenarios and risk assessment
• IUCLID file structure and endpoint records

What is unique to Turkey?

Company information, sole representative appointment documents, Turkish safety data sheet and local tonnage evidence are specific to Turkey. Additionally, the registration calendar and fee schedule are different. Therefore, copying and sending the AB file will not be enough; localization required.

Practical roadmap

First we extract the data rights scope of your EU file. Then we determine the forum situation and the leading recordist in Turkey. Then we negotiate the missing permissions and adapt the file to the KKS format. This way is both faster and significantly cheaper than registering from scratch.

Related pages

• Difference Between KKDIK and REACH
• EU REACH Registration Consultancy
• How to Prepare a Technical File?

Official full text of the regulation: KKDIK Regulation - Official Gazette.

For questions, contact ONAY Mühendislik.

A frequently asked detail: tonnage

Your tonnage in the EU and your tonnage in Turkey do not have to be the same. Registration obligation is calculated separately for each country. For example, a substance that is in a high band in the EU may remain in a low band in Turkey. In this case, a smaller data set would be sufficient and the access fee would also decrease. Therefore, clarify your tonnage for Türkiye before entering into negotiations.

Timing

Data rights negotiation often takes longer than technical preparation. Therefore, it is necessary to start the process months before the deadline. For the calendar, you can check our KKDIK registration calendar page.