Turkey Unveils Draft Implementation Rules for KKDIK, Sets Out Pre-Registration and Lead Registrant Deadlines

To boost compliance with Turkey's KKDIK chemical regulations, the Turkish Ministry of Environment and Urbanization published the Draft Implementation Rules in early 2025. These rules clarify key processes including pre-registration, Lead Registrant (LR) determination, and transitional periods, aiming to strengthen the lifecycle management of chemicals and standardize compliance across the industry. Here are the main points.

1. Pre-registration Deadlines

Substances produced/imported at >1t must be pre-registered via the Chemical Registration System (KKS) by June 30, 2025, and join MBDF.

For substances first produced/imported after June 30, 2025:

• 100-1000t/year: Pre-register by December 31, 2027.
• 1-100t/year: Pre-register by December 31, 2029.

2. Lead Registrant (LR) Determination

• For substances marketed before December 31, 2030, LR must be determined by September 30, 2025.
• LRs who haven't submitted registration dossiers need to communicate with MBDF on tonnage ranges, and data gap analysis, requiring approval from at least 70% of MBDF members.
• LRs confirmed before these rules take effect but without submitted dossiers must be re-confirmed under the new rules.

3. Transitional Registration

• LR must submit data listed in Annex 1 by December 31, 2025. Member companies must submit their registration dossiers to the Ministry of Industry and Technology by June 30, 2026.
• Companies completing full registration by December 31, 2025, are exempt from this.
• Transitional registration requires payment of statutory fees.

4. Safety Data Sheets (SDS)

Suppliers must prepare SDS in line with Turkish regulations and upload them to the dedicated SDS management system.

Note that this document is currently a consultation draft, and the final version will be adjusted based on industry feedback. Companies should clarify their pre-registration and transitional compliance obligations to avoid penalties, market bans, and operational disruptions.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

Draft.docx

Annex 1.docx