Ana sayfa/Who must register under KKDIK?
Who must register under KKDIK?
Any legal or natural person manufacturing or importing a substance into Turkey at 1 tonne per year or more — on its own, in a mixture or, under certain conditions, in an article — must register under KKDIK (Turkey REACH). The obligation lies primarily with the manufacturer and importer. Foreign manufacturers cannot register directly; they may appoint a Turkey-based Only Representative, in which case their importers become downstream users. Certain substance groups and uses benefit from special rules or exemptions. Clarifying your registration obligation requires expert assessment of your substance inventory and tonnage bands.
Related pages
Contact ONAY Mühendislik for KKDIK and REACH compliance support.
The four roles
Registration duties depend on your role. A Turkish manufacturer registers what it produces. An importer registers what it brings into Türkiye. A foreign manufacturer cannot register directly and appoints an only representative. A downstream user does not register but must confirm its use is covered.
The one tonne threshold
The calculation is made per legal entity and per calendar year. Quantities from several suppliers are added together, and a substance inside a mixture counts in proportion. Comparing the inventory against customs and purchasing records usually reveals volumes the regulatory team had not seen.
Frequent mistakes
- Counting domestic sales only and ignoring exports
- Assigning a single role to the whole portfolio
- Assuming the supplier has already registered on your behalf
- Leaving mixtures out of the tonnage calculation
What to do first
Build a substance inventory with CAS numbers and annual volumes, then assign the correct role to each line. Only after that does it make sense to look at forums, data costs and deadlines.
Related pages
Official source: KKDIK Regulation — Turkish Official Gazette.
Roles change by substance
One company can be an importer for one substance and a downstream user for another. Record the role per substance rather than for the portfolio as a whole, because that single note decides whether you register or merely verify. A blanket assumption almost always leaves a gap somewhere.
After confirming your role, continue with the procedure described in our guide to KKDIK registration.