KKDIK Late Pre-Registration After 31.12.2020

Key Points Regarding KKDIK Late Pre-Registration

1. Pre-Registration Phase

  • Under the new “Implementation Rules and Procedures (Usul ve Esaslar)” published in the Official Gazette on 12 August 2025, the KKDIK (Turkish REACH) regulation has introduced new timelines and obligations for pre-registration, Lead Registrant (LR) nomination, and full registration.

2. Pre-Registration Deadline

  • Companies that have already placed substances on the Turkish market must complete Pre-Registration via the KKS system by 31 October 2025.

  • For new substances placed on the Turkish market after this date, Pre-Registration must be submitted within 30 daysfrom the date the substance is first placed on the market.

3. Full Registration Requirement

For substances not pre-registered by the original deadline, companies must:

  • Submit an inquiry dossier through the KKS (Turkish Chemical Registration System).
  • Complete full registration before the substances can be legally placed on the Turkish market.

4. Deadlines for Full Registration

The updated full registration deadlines are based on annual tonnage and hazard classification:

a) 31 December 2026

  • Substances ≥ 1,000 tonnes/year.
  • Substances ≥ 100 tonnes/year classified as:
    • Aquatic Acute 1 (H400) or Aquatic Chronic 1 (H410).
  • Substances ≥ 1 tonne/year classified as CMR (Category 1A or 1B).

b) 31 December 2028

  • Substances ≥ 100 tonnes/year.

c) 31 December 2030

  • Substances ≥ 1 tonne/year.

5. What Does This Mean for Companies?

  • Although the pre-registration deadlines have not yet been officially determined, they will be specified in the forthcoming Procedures and Principles document published by the Ministry.
  • This document will provide clarity on:
    • Specific timelines for pre-registration.
    • Detailed requirements and processes for compliance.
  • Action Required:
    • Companies should closely monitor official announcements to stay informed.
    • Prepare in advance to meet the upcoming deadlines and ensure compliance.

Key Takeaways for Businesses

  1. No late pre-registration phase under KKDIK.
  2. Inquiry and full registration are mandatory for substances not pre-registered.
  3. Deadlines depend on tonnage and hazard classification.
  4. Await the Ministry’s Procedures and Principles document for final guidance.

Stay proactive to ensure compliance and avoid market disruptions. For further guidance on KKDIK requirements, feel free to reach out!