KKDIK explained for chemical suppliers to the Turkish market
KKDIK is Turkish REACH. Check who must register, the deadline tiers in the 2023 amendment, pre-SIEF status and separate Turkish Annex 17 restrictions.
KKDIK is Türkiye's regulation on the registration, evaluation, authorisation and restriction of chemicals, often called Turkish REACH. It creates Turkish obligations for substances manufactured in or imported into Türkiye, separate from EU REACH compliance. The general registration trigger is one tonne or more per year per manufacturer or importer, subject to exemptions. Some substance and product categories have separate rules. Source: KKDIK, Articles 2, 7 and 65.
For a supplier, the practical questions are who carries the Turkish duties, which deadline tier applies, whether a Turkish Only Representative covers the imports, and whether a restriction blocks the intended use. A registered substance must still meet the conditions of any applicable Turkish Annex 17 restriction. Source: Articles 7, 9 and 57.
What KKDIK means in English
The Turkish name is Kimyasalların Kaydı, Değerlendirilmesi, İzni ve Kısıtlanması Hakkında Yönetmelik, shortened to KKDİK. The original regulation appeared in Resmî Gazete on 23 June 2017, in issue 30105, Mükerrer. Article 65 says it was prepared taking Regulation (EC) No 1907/2006 into account within legislative alignment. That EU regulation is what people mean by EU REACH. Read the original official publication.
"Turkish REACH" is useful shorthand. It doesn't mean that every EU amendment automatically changes Turkish law. When you read KKDIK in English, keep the Turkish act and its amendments next to the translation. Check the applicable Turkish provision rather than treating the EU text as a substitute. Source: Articles 58 and 65.
The original publication is not a current consolidated text. Read its registration timetable with the 23 December 2023 amendment, Resmî Gazete No. 32408, which replaced the earlier schedule. Check later amendments before making a filing decision.
Who needs KKDIK registration?
Article 7 sets the general rule for manufacturers and importers. Unless another provision applies, they must apply through the Kimyasal Kayıt Sistemi, or KKS, for substances at one tonne or more per year. This covers substances on their own or in mixtures. The registration unit is the substance, not the commercial mixture as a whole. Source: Article 7.
Start with the substances in the supply chain, rather than assigning a registration status to a product name. For a mixture, assess its constituent substances separately. For each substance, establish the annual quantity and the manufacturer's or importer's role. Then check whether an exemption applies. Article 2 contains scope exclusions, while articles and polymers need separate consideration. Do not apply the substance-and-mixture threshold as a universal test for every product. Source: Articles 2, 7 and 8.
Downstream users also have duties concerning safe manufacture, marketing and use. That does not make every downstream user a registrant. Keep the registration assessment tied to the actual supply-chain role. Source: Articles 5 and 7.
The Only Representative route
A substance manufacturer, mixture formulator or article producer outside Türkiye may appoint an Only Representative established in Türkiye. Article 9 calls this representative a tek temsilci. The representative assumes the importer obligations covered by that provision. Source: Article 9.
The representative needs sufficient knowledge and specified, current supply-chain information. The appointing manufacturer must inform the importers in that supply chain. Those importers are then treated as downstream users under Article 9. Do not assume that every foreign distributor has the same appointment right. Source: Article 9.
For a supplier already using an EU Only Representative, check the Turkish arrangement separately. Establish who is appointed in Türkiye and which imports the appointment covers. An EU compliance arrangement alone does not establish that the Turkish Article 9 requirements are met. Source: Articles 9 and 65.
KKDIK registration deadlines in the 2023 amendment
The amendment published on 23 December 2023 set the following registration tiers. Its Article 7 replaced Provisional Article 2(1), and Article 9 made the amendment effective on publication. Source: the 2023 amending act.
| Deadline | Substances covered by the tier |
|---|---|
| 31 December 2026 | At least 1,000 tonnes/year; at least 100 tonnes/year classified Aquatic Acute 1 and/or Aquatic Chronic 1 (H400, H410); or at least 1 tonne/year classified carcinogenic, mutagenic and/or toxic to reproduction, category 1A or 1B |
| 31 December 2028 | At least 100 tonnes/year, unless an earlier tier applies |
| 31 December 2030 | At least 1 tonne/year, unless an earlier tier applies |
Source for all table entries: Resmî Gazete, 23 December 2023.
Match each substance to its earliest applicable tier. Tonnage alone is not enough. The hazard classes above can bring a substance into the 2026 tier at a lower quantity. The 2023 text applies those dates to Article 7 and/or Article 8, or to Article 17, or to Article 18. Its tier wording includes substances on their own, in a mixture or in an article. That still does not replace the Article 8 tests or the Article 2 exemptions. This guide does not set out Articles 17 and 18. Source: the 2023 amendment and original regulation, Articles 2, 7 and 8.
The table shows the schedule established by the 2023 act. It is not a complete filing calendar. Before acting, check subsequent amendments and current Turkish Ministry/KKS instructions, including any applicable interim requirements. A final registration date is not a reason to postpone checking the required procedure.
KKDIK pre-SIEF is not completed registration
In this context, pre-SIEF refers to the preliminary substance-information and supply-chain participation stage called ön-MBDF. The original Provisional Article 1 required prospective registrants to submit substance identity and supply-chain role information through KKS by 31 December 2020. That date describes the historical requirement, not a current filing window. Source: Provisional Article 1.
Keep the records separate. Evidence of a preliminary submission does not prove that Article 7 registration is complete or that all KKDIK duties are met. If a file contains only pre-SIEF information, establish the registration status and check the current Ministry/KKS procedure for that substance and company role. Source: Provisional Article 1 and Article 7.
Turkish Annex 17 and EU REACH Annex XVII
Turkish Annex 17, written Ek-17, contains restriction conditions. Article 57 prohibits manufacture, placing on the market or use contrary to an applicable restriction. Registration does not override those conditions. Source: Article 57.
EU REACH Annex XVII has the corresponding restriction function under EU Article 67. But suppliers must check the Turkish and EU provisions separately. Turkish Article 58 provides a mechanism for new or amended Turkish restrictions. Similar entry numbers do not establish identical current wording. Sources: Turkish Articles 57 and 58 and EU REACH, Article 67 and Annex XVII.
For each applicable Turkish entry, check substance identity, product and use scope, concentration conditions, exceptions and dates. Compare the EU entry separately when supplying both markets. A database search can help locate a record, but an absent result is not proof that Turkish law permits the use. Base the decision on the applicable legal conditions. Sources: Turkish Article 57 and EU Article 67.
What to check before supplying Türkiye
Use a substance-level review for each Turkish supply chain:
- Identify the substance, annual quantity and relevant hazard classification.
- Establish the manufacturer, importer or downstream-user role and check exemptions.
- Confirm any Turkish Only Representative appointment and the imports it covers.
- Match the substance to the deadline tier and check current Ministry/KKS filing instructions.
- Read the applicable Annex 17 conditions for the intended product and use.
RegAffairs AI provides a citation-backed answer on KKDIK registration and Turkish restrictions.
These checks address separate registration, representation and restriction duties. Keep the legal basis for each decision, rather than treating one preliminary filing or EU registration as the whole assessment. Sources: KKDIK, Articles 2, 7, 9 and 57, and the 2023 deadline amendment.