KKDIK Pre-Registration Services

KKDIK (Turkish REACH) requires companies to pre-register and register all substances that are manufactured in Turkey or imported into Turkey, either on their own, in mixtures, or in articles with an intended release, in quantities ≥ 1 tonne per year.

Foreign manufacturers exporting chemicals to Turkey must appoint an Only Representative (OR) to submit the KKDIK pre-registration (Pre-SIEF) and SEA (Turkish CLP) notifications on their behalf.
Compliance with KKDIK is mandatory for continued sales of chemicals and mixtures on the Turkish market.

🧾 Pre-Registration (Pre-SIEF / Pre-MBDF)

Under the new Implementation Rules (Usul ve Esaslar) published in August 2025, companies that have already placed substances on the Turkish market must complete Pre-Registration via KKS by 31 October 2025.
For new substances, pre-registration must be submitted within 30 days from the first import or manufacture.

1. Will there be fees for the pre- (SIEF) notification phase?

Pre-(SIEF) is free. There is actually no pre-registration term but a "pre-SIEF notification", which is free.

2. If a company supplies to the Turkish market currently is it mandatory to pre-SIEF?

Yes. Under the new 2025 Implementation Rules (Usul ve Esaslar), any company supplying or importing a substance ≥ 1 tonne per year to the Turkish market must complete a Pre-SIEF (Pre-Registration / Pre-MBDF) notification in the KKS system.

• Companies that were already placing substances on the market before 2025 must submit their Pre-SIEF notification by 31 October 2025.

• For new substances placed on the market after this date, Pre-SIEF must be completed within 30 days of the first manufacture or import.

Without Pre-SIEF, companies cannot join SIEF discussions or proceed with full KKDIK registration, and such substances cannot legally remain on the Turkish market.

3. What happens if a company wishes to manufacture or import a substance for the first time at >1tpa after the pre-SIEF deadline of 31 December 2020?

If a substance is supplied to the Turkish market for the first time since KKDIK entered into force at >1tpa in 2021, a pre- SIEF notification can be submitted until the end of the registration period in order to be part of the pre-SIEF (ön-MBDF) discussion and MBDF (SIEF) joint registration.

4. Can a company decide not to submit a Pre-SIEF notification, then later change their mind?

Yes. Under the updated 2025 Implementation Rules (Usul ve Esaslar), the Pre-SIEF (Pre-Registration / Pre-MBDF) module in KKS remains open and functional even after the initial deadline.

• Companies that have not submitted their Pre-SIEF by the earlier deadlines (e.g., 2020 or 2023) can still submit a late Pre-SIEF if they intend to start manufacturing or importing a substance ≥ 1 ton per year after those dates.

• For existing substances already on the Turkish market, Pre-SIEF must now be completed by 31 October 2025.

• For new substances introduced after that date, the Pre-SIEF must be submitted within 30 days of first manufacture or import.

Submitting a late Pre-SIEF enables the company to:

• Join the relevant SIEF discussions for data and cost-sharing,

• Proceed with joint registration, and

• Ensure full compliance with KKDIK before the applicable registration deadlines (2026–2030).

However, failure to pre-register in due time may lead to temporary market restrictions and penalties once the corresponding registration deadline passes.

5. If a company supplies a substance for the first time (after 2025) at >1 tpa, when must the Pre-SIEF be submitted?

Under the new 2025 Usul ve Esaslar, there is now a defined timeframe for first-time suppliers:

• For substances placed on the Turkish market after 31 October 2025, the Pre-SIEF (Pre-Registration / Pre-MBDF) must be submitted within 30 days from the date the substance is first manufactured or imported at quantities ≥ 1 tonne per year.

This replaces the earlier uncertainty under the previous version of the regulation (which prescribed no specific period).
Failing to notify within this 30-day period would mean the company cannot lawfully manufacture or import that substance until the Pre-SIEF notification is completed.

6. When does the ability for Pre-SIEF notification end for first-time manufacturers and importers?

Under the new KKDIK Implementation Rules (Usul ve Esaslar, 2025), the Pre-SIEF (Pre-Registration / Pre-MBDF) module will remain open throughout the entire KKDIK registration period.

This means that:

• The ability to submit Pre-SIEF notifications will continue until the final registration deadline (31 December 2030).

• For any substance manufactured or imported ≥ 1 tonne per year for the first time after 31 October 2025, the company must first submit an inquiry file through KKS to confirm whether a registration already exists for that substance.

• Once verified, the company must complete the Pre-SIEF notification within 30 days of the first manufacture or import.

In short, Pre-SIEF notification does not end in 2023.
It remains available throughout the KKDIK registration period (2025 – 2030) to allow new market entrants to comply before starting manufacture or import activities.

7. How do we know who has submitted a pre-SIEF notification already for a given substance?

This can only be seen through Chemical Registration System, when potential registrants submit pre- SIEF notifications for the same substance(s)

8. Is there the ability to claim CBI on substance identity information when pre-SIEF-notifying substances? Some of these may perhaps be claimed as CBI elsewhere in the world and if the full substance identity is published under KKDIK it could undermine efforts made to protect CBI elsewhere in the world.

There is no way but one to protect CBI within the pre-SIEF process and this would be to request an alternative name.
There are no terms such as “phase-in substances” or “NONS” in KKDIK.

What are our main KKDIK pre-SIEF (pre-registration) services?