Introduction
The Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) has announced substantial changes to Turkey’s chemical regulation, KKDIK. These announcements have significantly reshaped the registration landscape for all companies manufacturing, importing, and placing chemical substances on the Turkish market.
The most impactful changes are:
- The MoEUCC has introduced a new Individual Temporary Registration pathway, allowing companies to register without a Lead Registrant in place.
- All companies must now obtain either a full or temporary registration number for the substances they wish to continue placing on the market by 30 September 2026.
The updates aim to make the registration process simpler, faster and more efficient while ensuring Turkey has a national chemical inventory in place as soon as possible. But they impose urgent obligations on companies in Turkey or those who have appointed an Only Representative (OR).
Full details of the changes are explained below.
New Individual Temporary Registration Pathway
Registration in Turkey has been slow to progress due to many substances not having Lead Registrants appointed, or issues with data sharing where a Lead Registrant has been appointed. As a result, to ensure registration can progress while this issue is resolved, the MoEUCC has introduced an Individual Temporary Registration pathway within the Chemical Registration System (KKS).
This pathway:
- Allows companies to proceed independently where no Lead Registrant exists
- Removes the ability to cite the lack of Lead Registrant appointment as a reason for non‑compliance
- Ensure all registrants can meet the 2026 deadline
To complete an Individual Temporary Registration, companies must use the KKS system and include information required under Annex I of the KKDIK Procedures and Principles. If any of the information cannot be fulfilled, a justification should be included documenting the missing information and why full registration cannot be submitted.
By the relevant deadline in 2026, 2028, or 2030, companies will then need to submit a full registration dossier with all the information required for the relevant tonnage band.
Mandatory Full or Temporary Registration by 30 September 2026
The MoEUCC has imposed a new deadline and all substances within the scope of KKDIK registration must have either a Full or Temporary registration in place by 30 September 2026, regardless of tonnage band, hazard class, or whether a Lead registrant has been appointed.
This represents a significant shift away from previous expectations, where co‑registrants could wait for their relevant registration deadline in 2026, 2028, or 2030, provided the Lead registrant had submitted a full registration dossier.
Failure to obtain a full or temporary registration number by the 30 September deadline will prevent continued market access. The MoEUCC has indicated that an inspection system will be established which introduces controls at customs based on the relevant registration number and substances without a registration number will not be allowed to be placed on the Turkish market.
Summary
Companies seeking continued access to the Turkish market must now:
- Determine their most appropriate registration pathway
- Secure a full or temporary registration number for every applicable substance by the 30 September deadline
- Prepare for post‑deadline inspections and ongoing dossier updates
If you have any questions about the changes to the KKDIK regulation, and how these impact your business, please contact us!
Published March 13th, 2026
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