KKDIK Explained
What is KKDIK?
KKDIK is Türkiye's chemicals regulation, modelled on EU REACH. The name stands for Kimyasalların Kaydı, Değerlendirmesi, İzni ve Kısıtlanması Hakkında Yönetmelik, the Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals. It was published in the Turkish Official Gazette on 23 June 2017 (No. 30105) and is run by the Ministry of Environment, Urbanisation and Climate Change (Resmî Gazete, 23.12.2023).
How it mirrors REACH
- Registration: substances made in or imported into Türkiye at 1 tonne/year or more must be registered.
- Authorisation and restriction: these work like REACH. KKDIK has its own Annex 17 (EK-17), a list of restrictions that is binding in Türkiye. The Ministry publishes it in Turkish, which is the legal text, and in an official English translation. Its entries follow the same pattern as the EU's Annex XVII. For example, entry 5 (benzene) bans benzene as a substance or in mixtures at 0.1% by weight or more, and bans it in toys above 5 mg/kg, with exemptions such as motor fuels [1].
Registration deadlines (amendment of 23 December 2023) The amending regulation took effect on its publication date. It pushed the general deadline back from 31 December 2023 to 31 December 2030 and set staged deadlines:
| Deadline | Substances covered |
|---|---|
| 31 Dec 2026 | ≥1,000 t/year; or ≥100 t/year classified Aquatic Acute 1 / Aquatic Chronic 1 (H400, H410); or ≥1 t/year classified as carcinogenic, mutagenic or toxic to reproduction (CMR) Cat. 1A/1B |
| 31 Dec 2028 | ≥100 t/year |
| 31 Dec 2030 | ≥1 t/year |
The same amendment also allows joint registration procedures through the Union of Chambers and Commodity Exchanges of Türkiye (TOBB) (Resmî Gazete, 23.12.2023).
The first deadline is 31 December 2026, about two months from now. It covers high-tonnage, CMR and aquatic-toxic substances.
Approach: I used the KKDIK Annex 17 restriction list and read the 2023 amendment in the Turkish Official Gazette. I couldn't open the Ministry's chemicals portal (kimyasallar.csb.gov.tr), so the 2017 publication details come from the reference to it in the 2023 amendment.
When do companies need to register?
Under the 23 December 2023 amendment to KKDIK, registration runs in three phases set by tonnage and hazard. The first deadline is 31 December 2026, about two months away (Resmî Gazete, 23.12.2023).
| Deadline | Who must register by then |
|---|---|
| 31 Dec 2026 | Substances on their own or in mixtures at ≥1,000 t/year; or ≥100 t/year classified as hazardous to the aquatic environment (H400, H410); or ≥1 t/year classified as carcinogenic, mutagenic or toxic to reproduction (CMR) Category 1A/1B |
| 31 Dec 2028 | Substances on their own or in mixtures at ≥100 t/year |
| 31 Dec 2030 | Substances at ≥1 t/year |
How it works in practice
- Find your earliest deadline by checking each substance's annual tonnage and its classification. A low-tonnage substance still falls in the 2026 group if it is a Category 1A/1B CMR, and a 100 t/year substance does too if it is classified H400 or H410.
- The amendment moved two other dates in KKDIK: 31/12/2023 became 31/12/2030, and 31/12/2025 became 31/12/2032.
- The amendment took effect on 23 December 2023, the day it was published.
I found no later amending regulation in the Official Gazette that changes these dates.
Approach: I checked the KKDIK sources in the datasets, which cover the Annex 17 restriction list and the Turkish chemical inventories but not the registration articles. So I took the deadlines from the 2023 amendment in the Turkish Official Gazette, and searched the Gazette for anything newer.
How do Turkish restrictions compare with EU REACH?
Türkiye's KKDIK Annex 17 (EK-17) is a near word-for-word copy of the older part of EU REACH Annex XVII. It covers every EU entry from 1 to 66 and uses the same numbers and largely the same conditions. It then stops: the EU list runs to entry 83, so 16 EU restrictions have no Turkish equivalent. Türkiye also has two entries the EU data does not hold: a national cyanide entry (67) and pentachlorophenol (22).
How the lists line up
- KKDIK EK-17 has 54 entries in both its Turkish legal text and the Ministry's English translation. Several EU entries are grouped under one Turkish heading:
- Where the two match, the core limits are the same. Two examples:
- The Turkish text points to national law instead of EU law. Examples are the Turkish CLP bylaw, TS EN 14059 for decorative oil lamps, the Turkish Food Codex and Turkish customs tariff codes. Several of its dates also differ from the EU's.
Shared entries where the EU text goes further
| Entry | KKDIK EK-17 | EU Annex XVII |
|---|---|---|
| 51 Phthalates | DEHP, DBP and BBP; toys and childcare articles only [11] | Adds DIBP. Also bans the four phthalates at 0.1% or more in articles generally after 7 July 2020, with derogations [12][13] |
| 50 PAHs | Extender oils, tyres, consumer articles, toys (paragraphs 1-7) [14] | Also covers granules and mulches used as infill or on playgrounds: 20 mg/kg limit for the sum of PAHs, from 10 August 2022 [15] |
| 63 Lead | Jewellery and articles children may put in their mouths [9] | Adds lead gunshot in and near wetlands (after 15 February 2023). Adds lead in PVC at 0.1% or more, from 29 November 2024, with derogations for recovered PVC [10][16] |
| 28-30 CMRs | Derogations (a) to (c): medicines, cosmetics, fuels [3] | Also derogates (d) artists' paints and (e) the substances in Appendix 11 [17] |
EU entries with no KKDIK equivalent (16)
| EU entry | Restriction |
|---|---|
| 68 | C9-C14 PFCAs, their salts and related substances [18] |
| 69 | Methanol in windscreen washing or defrosting fluids for the general public [19] |
| 70 | Cyclic siloxanes D4, D5 and D6 [20] |
| 71 | NMP (worker exposure limits) [21] |
| 72 | CMR substances in clothing, textiles and footwear [22] |
| 73 | TDFAs (fluorinated silanes) in consumer spray products [23] |
| 74 | Diisocyanates (training required for industrial and professional use) [24] |
| 75 | Substances in tattoo inks and permanent make-up [25] |
| 76 | DMF (worker exposure limits) [26] |
| 77 | Formaldehyde released from articles, after 6 August 2026 [27] |
| 78 | Synthetic polymer microparticles (microplastics) [28] |
| 79 | PFHxA and related substances, from 10 October 2026 [29] |
| 80 | DMAC (worker exposure limits), after 23 December 2026 [30] |
| 81 | NEP (worker exposure limits), after 23 December 2026 [31] |
| 82 | PFAS, Regulation (EU) 2025/1988 |
| 83 | 2,4-Dinitrotoluene in articles, after 10 May 2027 [32] |
What Türkiye has that the EU data does not
- Entry 67, cyanide compounds, added in 2019. It covers hydrogen cyanide and its salts, and calcium, sodium, potassium, copper, zinc and cadmium cyanides. The rules are [33]:
- They "shall not be placed on the market, on internet or any other electronic medium for supply to the general public".
- Packaging must carry "This product is only for professional and industrial use".
- Downstream users and distributors must give an End-user Declaration (Appendix 11 of the Turkish annex) to their manufacturer or importer.
- Manufacturers and importers must send these declarations to the Ministry in March, June, September and December each year.
- Note that Appendix 11 means different things in the two lists. In Türkiye it is this declaration form; in the EU it is the list of substances derogated from entries 28-30.
- Entry 22, pentachlorophenol and its salts and esters: banned as a substance, and in mixtures at 0.1% or more [34]. The EU Annex XVII data hold no entry 22.
In practice: meeting KKDIK EK-17 does not make a product EU-compliant. Microplastics, PFHxA, PFAS, formaldehyde emissions, the diisocyanate training duty, and phthalates or lead in general articles and PVC are all EU-only. In the other direction, cyanide suppliers in Türkiye have duties (no online sales to the public, end-user declarations, quarterly reporting) that I found no EU entry for.
I searched the Turkish Official Gazette and found no amendment to EK-17 after entry 67. I could not open the Ministry's KKDIK amendment announcement on cygm.csb.gov.tr (link).
Approach: I compared all of the KKDIK EK-17 list, in both the Turkish text and the official English translation, with the EU REACH Annex XVII conditions of restriction published by ECHA. I also searched the Turkish Official Gazette for newer EK-17 amendments.
Sources: Resmî Gazete, 27.12.2025 (checked, not a KKDIK act)