30 September 2026 is the KKDİK provisional registration deadline across tonnage bands: companies manufacturing or importing substances at 1 tonne or more per year must complete provisional registration by this date. A substance without a provisional registration number may not be placed on the market afterwards. This also concerns everyone purchasing that substance. This article provides a checklist for buyers.
Why does temporary registration concern the buyer?
If your supplier has not been temporarily registered, he will not be able to sell that item to you as of October 1, 2026. If your production line depends on a single raw material supplier, your compliance becomes dependent on his schedule. The question asked in the audit is also clear: from whom did you purchase this substance, what is the registration status of the supplier, where is the document?
Therefore, the work to be done in the remaining months of 2026 does not end with completing your own registration; scanning your supply chain and marking risky substances
What will you ask from the supplier?
| Document / information | Why is it necessary | How to verify |
|---|---|---|
| Temporary registration number | Availability of the substance after 30.09.2026 | Written declaration and specification in SDS |
| Current Turkish SDS | 16 episodes, KKDIK format | Registration information in Chapters 1 and 15 |
| Letter for appointment of sole representative | Who is responsible for imports? | Designation certificate from the manufacturer |
| Tonnage covered | Is your purchase covered? | Tonnage band in assignment/declaration text |
| Substance identification (CAS/EC) | The declaration actually refers to the item you received. | Comparison with SDS Part 3 |
The last line seems unimportant, but it is the most frequently overlooked check: the supplier can send the registration information for another item in its portfolio. Always match the number you receive with the CAS number of the item you received.
If you are importing: who really has the liability?
- If the manufacturer has appointed a sole representative: the obligation to register is with the representative, you become a downstream user. However, this is subject to the condition that the assignmentincludes your imports. The list of importers covered by your company or representative should appear in the appointment letter.
- If there is no assignment: the liability lies directly with you. You will make the temporary registration.
There is another intermediate situation and this is the most risky one: the appointment has been made but the tonnage is limited. If the manufacturer's representative is appointed for 50 tons, 30 tons of your 80-ton purchase will be out of scope. For details, see Is it mandatory to appoint a sole representative page.
Temporary registration does not replace full registration
The provisional registration is an intermediate station: it keeps the substance on the market, but does not relieve the technical file obligation. deadlines for full registration vary depending on tonnage and hazard class:
| Status | Full registration deadline |
|---|---|
| 1,000 tons/year and above | December 31, 2026 |
| CMR Category 1A/1B, above 1 tonne/year | December 31, 2026 |
| Aquatic Acute 1 / Chronic 1, over 100 tons/year | December 31, 2026 |
| 100 – 1,000 tons/year | December 31, 2028 |
| 1 – 100 tons/year | December 31, 2030 |
You can see which line your item falls into with its CAS number on our deadline and cost tool, and you can read the difference between the two registration types on the temporary registration and full registration difference page.
Pre-September to-do list
- Remove item-by-item annual quantities from purchasing records — total by item, not by supplier.
- Flag items that exceed the 1 tone threshold.
- Send a written request for information to the supplier for each; File the answer and date.
- For unresponsive or unregistered suppliers, start searching for alternative sourcing now.
- If you have your own obligations, do not postpone the temporary registration until the last week of September; System intensity and missing information corrections take time.
Our September 30, 2026 audit preparation page is helpful for the preparation on the audit side, and our enforcement of non-registration page is helpful for the enforcement side of non-compliance.
Frequently asked questions
Where will I see the temporary registration number?
The number is given to the registrant by the system and is usually stated in the relevant section of the Safety Data Sheet. Request written confirmation from the supplier.
My supplier says "we have a registration" but does not provide documentation. Is it enough?
Verbal statements are useless in an audit. Request written confirmation and item matching, even at the email level.
Is provisional registration required for substances under 1 tonne?
No. The threshold is 1 tonne per year; However, liability arises if the threshold is exceeded during the year, so keep an eye on tonnage.
I have provisionally registered, am I done?
No. The technical file (IUCLID/KKS) process for full registration is carried out separately and must be completed in 2026, 2028 or 2030 depending on your tonnage band.
We can conduct supply chain scanning and provisional registration applications on your behalf — contact us.
Official full text of the regulation: KKDIK Regulation - Official Gazette.