March 25, 2026

KKDIK Update: Temporary Registration Pathways Clarified

Karen Lorusso Bergeson & Campbell, P.C. + Follow Contact LinkedIn Facebook X Send Embed

The Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) has released an executive summary clarifying temporary registrations and temporary individual registrations under KKDIK (Kimyasalların Kaydı, Değerlendirilmesi, İzni ve Kısıtlanması). The announcement addresses situations where companies have pre-registered substances but cannot proceed with joint registration due to the absence of a lead registrant. In these cases, companies may submit a temporary individual registration, allowing them to remain compliant while the joint registration framework is still being established.

The establishment of the national chemicals inventory remains of critical importance to MoEUCC. To this end, companies must complete a full registration, temporary registration, or temporary individual registration by September 30, 2026, regardless of tonnage band. Where certain required information cannot be submitted or obtained by September 30, 2026, a temporary registration dossier may still be submitted, provided that the missing information is documented and justified. Once a temporary registration is submitted, the full registration requirements are due by the deadline depending on the tonnage band. The deadlines may be extended by two years. The registration deadlines are below.

• December 31, 2026:
  • Substances that are manufactured or imported at or above 1,000 metric tons per year (mt/y);
  • Substances that are manufactured or imported at or above 100 mt/y and classified as Aquatic Acute Category 1 and Aquatic Chronic Category 1; and
  • Substances that are manufactured or imported at or above 1 mt/y that are classified as carcinogen, mutagen, and/or toxic to reproduction in Category 1A and 1B.
• December 31, 2028:
  • Substances that are manufactured or imported at or above 100 to less than 1,000 mt/y.
• December 31, 2030:
  • Substances that are manufactured or imported at or above 1 to less than 100 mt/y. Beginning October 1, 2026, all substances manufactured or imported into Turkey must have a full or temporary registration submitted. Authorities will begin verifying that substances have a valid registration number after this date. For substances manufactured or imported into Turkey for the first time after September 30, 2026, an inquiry must be submitted before manufacture or import to obtain a registration number.

Companies should review their pre-registrations now and determine the appropriate path forward, particularly in cases where no lead registrant has yet been identified. Early preparation is critical to maintaining market access in Turkey. Acta closely monitors KKDIK regulatory developments and is prepared to assist companies in developing practical compliance strategies and managing evolving compliance obligations.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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