Foreign manufacturers exporting chemicals to Turkey face specific KKDIK obligations. They cannot register directly and must act through a Turkey-based Only Representative.
Key points: build a substance inventory and tonnage plan; appoint an Only Representative; join the relevant MBDF and share data; prepare the IUCLID dossier and, above 10 tonnes, a Chemical Safety Report; and complete registration by 30 September 2026. Under the ‘no data, no market’ principle, unregistered substances can be blocked from the market.
ONAY Mühendislik manages the entire KKDIK process for foreign manufacturers.
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Contact ONAY Mühendislik for KKDIK and REACH compliance support.
Yönetmeliğin resmî tam metni: KKDİK Yönetmeliği — Resmî Gazete.
You cannot register from abroad
A manufacturer outside Türkiye cannot file a registration directly. The obligation is met either by appointing a Türkiye-based only representative or by leaving registration to each importer. The first route produces one registration; the second multiplies cost and exposes your formulation to several trading partners.
What you need to prepare
Expect to provide a signed appointment letter, current company records, analytical substance identity, annual volumes per importer and any study data you already own. Missing analytical data is the single most common reason these projects stall in the first month.
After the registration is filed
The work continues. Volumes are tracked every year, and crossing a tonnage band means updating the dossier. A change in classification feeds through to the Turkish safety data sheet and the label, so the document set has to be reviewed as a whole rather than page by page.
Your importers change status
Once an only representative is appointed, the importers it covers become downstream users. That change must be communicated in writing, because it alters their obligations. Importers outside the appointment keep registering on their own, so the covered list has to be accurate and current.
Confidentiality is part of the decision
Leaving registration to importers means sharing composition data with several commercial partners. A single representative keeps that information with one contracted party. For many exporters this weighs more heavily than the cost comparison.
What Foreign Manufacturers Should Ask Their Importers
Foreign manufacturers often assume their Turkish customers have already handled registration. Ask each importer, in writing, which substances they register, under which tonnage band, and whether they rely on an Only Representative. Foreign manufacturers who collect these answers early can see whether a single representative would serve the whole customer base at a lower total cost.