FREQUENTLY ASKED QUESTIONS

Frequently asked questions is the application page that brings together the technical answers to the most frequently asked questions to ONAY Mühendislik regarding KKDIK registration, EU REACH, Exclusive Representation, Safety Data Sheet, UFI/PCN notification and MBDF. Answers have been prepared in accordance with current Turkish legislation; A separate evaluation is required for the scope specific to your company.

KKDIK record

KKDIK registration is a legal prerequisite for companies supplying substances to the Turkish market. Determination of the scope is made by evaluating the identity of the substance, its annual tonnage and the role of the company in the supply chain.

What is KKDIK and who does it cover?

KKDIK is the abbreviation of the Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals. It obliges companies that manufacture or import one ton or more of substances per year in Türkiye to register these substances through the Chemical Registration System (KKS). The liability covers the substance itself, the substances in the mixture and, under certain conditions, the substances contained in the article.

When is the KKDIK registration deadline?

Registrars within the scope of KKDIK must complete the individual provisional or full registration obligation by September 30, 2026, regardless of tonnage and whether there is a lead registrar. Final full registration dates are determined according to the relevant tonnage and hazard calendar.

How do we determine our recording scope?

Scoping determination; It is done by creating a list of substances and products, verifying the CAS/EC identity for each substance, determining the role of the company as a manufacturer or sole representative if there is no importer, and calculating the annual tonnage band. Tonnage alone does not result in exclusion; Usage and exemption information should also be evaluated together.

EU REACH and export

EU REACH and KKDIK are separate legislation and require separate registration. A registration made in Türkiye is not valid for the European Union market.

What is the difference between EU REACH and KKDIK?

Both are based on registration, evaluation and restriction logic; but are subject to different authorities, different schedules, and different filing requirements. EU REACH registration is done at the European Chemicals Agency, and KKDIK registration is done through the Chemical Registration System. Registration in one market does not exclude liability in another.

What obligations arise when exporting to the European Union?

For Türkiye-based companies supplying substances or mixtures to the EU, the liability generally falls on the importer in the EU. If the manufacturer wishes to take on this burden, it can appoint an Only Representative based in the EU to carry out the registration on its behalf. The right model is determined after product, customer and annual tonnage analysis.

Does UK REACH require a separate registration?

Yes. Following the United Kingdom's departure from the European Union, UK REACH became an independent registration regime. EU REACH registration does not apply to the UK market; If supply to this market is to continue, a separate registration or representative structure must be established.

Only Representative

The Only Representative is the legal representative established within the country who carries out the registration obligation of the manufacturer located abroad on his own behalf. If it is not appointed, the liability passes to the importers.

What is Only Representative?

A manufacturer located outside Türkiye may fulfill its obligations under KKDIK through an Only Representative located in Türkiye. If an Only Representative is not appointed, the registration obligation falls on the relevant Turkish importers.

What is the advantage of appointing a Only Representative?

With Only Representative the manufacturer retains control of the registration file and data ownership; There is no need for each customer to register separately. This structure both protects the confidentiality of composition information and prevents duplicate registration and costs among importers.

Who can be a Only Representative?

Legal entities located in Türkiye with sufficient capacity to prepare chemical regulatory files and carry out technical correspondence with the authority can be appointed as Only Representatives. In practice, this role is undertaken by a consultancy organization that can continuously manage substance identity and tonnage tracking.

Safety Data Sheet (SDS/SDS)

Safety Data Sheet is a 16-section document describing the safe use of harmful substances and mixtures. Its preparation is based on the classification made according to the CLP Regulation.

What is a Safety Data Sheet (SDS)?

SDS is a document that describes the composition of a substance or mixture, hazard classification, safe use conditions and emergency measures in 16 sections. In Türkiye, it must be prepared in Turkish and in accordance with the legislation in force.

When should the SDS be updated?

The SDS must be rearranged when there is a change in the product composition, when the hazard classification changes, when new toxicological or physical-chemical data are obtained and when the relevant legislative provisions are updated. The updated form must be forwarded to buyers in the supply chain.

Why might SDS and label information look different?

The label carries only basic hazard communication in a limited area; SDS, on the other hand, explains in detail the entire rationale and conditions of use of the same classification. The two must derive from the same classification; If there is a difference, this is a sign of inconsistency and requires technical control.

Code UFI and notification PCN

UFI code and PCN notification are separate steps. Generating code alone does not complete the notification obligation.

What is a UFI code and how is it generated?

UFI is a sixteen-character code that uniquely identifies the formula of harmful mixtures. It is produced using the company's tax number and the formula number given to the mixture and is included on the product label. The code generated for the same formula remains constant as long as the formula does not change.

Does receiving a UFI code complete PCN notification?

No. Generating a UFI code is only the first step; The PCN notification to the poison control center must be prepared and sent separately. The notification includes the composition of the mixture, hazard classification, packaging and product category information.

When is the PCN notification updated?

Changes to the formula, hazard classification, product description, trade name or packaging information may require updating the notification. It should be technically evaluated whether each change triggers the notification.

MBDF and data sharing

MBDF is the structure created for data sharing by companies that will register the same substance. Its purpose is to prevent duplicate testing and share the cost.

What is MBDF?

MBDF stands for Substance Information Exchange Forum. It is a structure where companies that will register the same substance come together, share existing data, produce missing data together and prepare a joint registration file. Its aim is to prevent unnecessary animal testing and the cost of duplicate testing.

What does a lead logger do?

Lead registrar is the company that prepares the joint registration file on behalf of MBDF members and submits it to the authority. Responsible for identifying the substance, closing data gaps and ensuring the technical integrity of the dossier. Other members complete their own records based on this common file. Detail: What is a lead recorder and how is he selected?

What is a Letter of Access (LoA)?

LoA is the document that gives the right to reference data in the common registry file. The company, which contributes to the cost of the party producing the data, can use this data in its own record through LoA. Attribution without LoA is invalid in terms of data ownership.

Related pages

For detailed explanation of the subject headings: What is KKDIK · KKDIK consultancy services · KKDIK registration calendar 2026 · KKDIK registration fees 2026 · KKDIK administrative fines · REACH registration · sole representation · Safety Data Sheet (SDS) · UFI code and PCN notification · MBDF management · SEA Directive · regulatory announcements.

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