KKDİK 2026 Process: What Needs to Be Done for Individual Temporary Registration or Full Registration by September 30, 2026 - KKDİK 2026 Temporary Registration and Full Registration Guide
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The KKDİK application has entered a critical phase in 2026.
KKDİK 2026 Temporary Registration and Full Registration Guide: What Needs to be Known?
Following the announcement from the Ministry on March 4, 2026, companies need to clarify their registration strategies without delay as part of the establishment of Turkey’s chemicals inventory.
KKDİK is the fundamental registration and evaluation system implemented in Turkey to control the effects of chemical substances on human health and the environment. The main principle of the system is that companies offering the same substance collaborate and share data within a common registration structure. However, due to issues such as the inability to designate a leading company, failure to complete data sharing, disputes over cost-sharing, and the insufficient maturation of technical files, the process has slowed down for many substances.
The ministry’s announcement dated March 4, 2026, is extremely important in this regard. The announcement clearly states the significance of creating an inventory of chemicals in our country and expresses that companies should make individual temporary registrations related to chemicals without regard to tonnage by September 30, 2026.
The implication of this approach is as follows:
September 30, 2026, is no longer just a technical interim stage; it is a critical threshold where the Ministry expects visibility and traceability in the system for the substances covered by registration offered in the Turkish market.
Final deadline: September 30, 2026
Method: Temporary registration or full registration
Risk: Requirement for audit and pre-market registration
The third of these is based on the registration auditing of substances manufactured/imported after September 30, 2026, and the requirement for a pre-activity application for new substances.
What does the Ministry's announcement regarding KKDİK on March 4, 2026, mean?
The Ministry’s text has several important implications.
First, the temporary registration approach has been raised regardless of tonnage. This means that companies can no longer rely solely on the attitude of “my final registration date is later, so I can wait.” For the purpose of inventory creation, it is expected that the relevant substance will be registered in the system.
Secondly, even if some information within the scope of the Procedures and Principles Annex-1 cannot be obtained, these deficiencies can still be documented in the KKS with justifications, allowing a temporary registration file to be submitted. This provides significant flexibility in practice, as it enables many companies to initiate the process without finalizing analytical data, usage information, or other technical content. It is also clearly stated that any missing information can be updated until the final registration dates.
Thirdly, the audit message for the period after September 30, 2026, is very strong. The Ministry states that necessary audits concerning the queries of temporary registration numbers for substances manufactured or imported by companies will be conducted after this date. Furthermore, it indicates that a temporary or full registration application must be made prior to the activities for new substances to be manufactured or imported after September 30, 2026. This should be interpreted as effectively closing the period for market entry without registration.
Fourthly, granting member companies the right to individual temporary registration with justification, even for a substance for which a complete registration file has been previously submitted by the leading company, shows that the Ministry has established a flexible but supervised model in practice. Disproportionateness in cost sharing, confidentiality concerns, or differences of opinion have been specifically mentioned.
Who is being affected?
This new approach is directly relevant for the following groups:
Companies manufacturing substances in Turkey.
Companies importing substances independently into Turkey.
Companies importing or formulating mixtures; because registration assessment is conducted on a substance basis, not a mixture basis.
Foreign manufacturers with multiple importers in Turkey.
Foreign manufacturers that have established a registration strategy through a Only Representative.
MBDF/SIEF participants awaiting a leading company or experiencing a blockage in the data sharing process.
A point that requires particular attention from mixture importers is clarifying who will cover each registered substance within the mixture in Turkey. Otherwise, everyone in the supply chain may assume that another party will handle the registration, leaving the substance effectively unaccounted for.
What application methods are available?
Full Registration
If the data package and registration strategy regarding the substance are sufficient, a direct full registration can be made. The Ministry has also clearly stated that companies that receive a full registration number do not need to obtain a temporary registration number.
Joint temporary registration / joint registration
If a leading company has been determined and the joint structure (MBDF) is operational, either a temporary registration or a full registration strategy can be implemented through the leader. In announcements regarding the sector after 2025, interim deadlines for the leading company and member firms have been approached with this rationale.
With this announcement, the deadline for firms wishing to complete temporary registrations, either through the leader or joint temporary registrations, has also been unified to September 30, 2026. It is important to note that in MBDFs where a leader has not been appointed, joint temporary registrations cannot be made, so joint registrars have been directed towards individual temporary registration.
Individual temporary registration
If a leading firm has not been identified, a joint registration structure has not been established, discussions on data sharing have been inconclusive, or if it is not possible to proceed within a joint file due to reasons such as cost, privacy, and differences of opinion; individual temporary registration becomes a strong alternative.
The ministry’s announcement clearly states that the individual temporary registration was implemented specifically for this purpose, requiring companies that cannot make full registrations, joint registrations, or joint temporary registrations to complete their individual temporary registrations, independent of tonnage, by September 30, 2026.
How is the individual temporary registration progressing on KKS?
Temporary Registration – Chemical Registration System (CRS) (Individual)
Submission Steps for the Temporary Registration of a Submitted Substance to the Pre-MBDF
Enter the Substance Management section from the left menu in the KKS system.
The topic is selected as Registration..
The relevant substance is selected..
Press the Go to substance button.
Select “KKDIK Temporary Registration” from the opened templates.
The sections designated for temporary registration are filled out..
Go back to the Substance Management section..
Press the Send Substance button..
Select “Temporary Registration of KKDIK” as the registration type..
In the “Joint Application Section,” select “No.”
It is confirmed that the revolving fund fee generated by the system is consistent with the weight information entered in Section 1.1..
The dossier submission is completed by following the Next tab and Submit Substance steps..
Payment Process
After the submission of the substance, a “Payment Reference Number” specific to the application is assigned by the system.
At this stage, when the relevant substance is clicked on the Sent Substances screen, the information “Payment Made: No” will be displayed.
Payment is made to the bank by stating the reference number shown on the screen.
After the payment is made, the company must click on the relevant substance again in the Sent Substances screen to transfer the payment information to the KKS..
When the warning “Payment Made: Yes” is displayed on the system, the application is taken into the Ministry’s evaluation process.
Attention: It is critically important that the warning “Payment Made: Yes” indicated in step 5 above is displayed. Otherwise, there may be delays in the acceptance of the dossier.
Missing Data and Documents
If there is data that cannot be obtained while filling out temporary registration sections, the registration is made by writing the justification in the relevant section.
If there are existing documents regarding this, they are uploaded to section 13.2 Other Assessment Reports.
The Chemical Assessment Specialist Certificate is also added to section 13.2 Other Assessment Reports.
Can an application be made with missing data?
Yes, it can be done to a certain extent.
The official text of the Ministry clearly states that temporary registration dossiers can be sent, provided that the reasons for any missing information under the Scope of Procedures and Principles Appendix-1 are specified in the KKS. However, this is not an exemption; missing information and documents must be updated by the final registration dates indicated in the regulation.
Therefore, the ability to register temporarily with incomplete data should be interpreted not as “complete data is not required,” but rather “the process can be initiated with justification, but the dossier must be completed later.”
Remember that temporary individual registration is a bridge on the way to full registration. Temporary individual registrations will also turn into common registration dossiers in the next step under the “One Item One Registration” principle.
Submission of Temporary Individual Registration is not the same as submission of Full Individual Registration dossiers.
What will happen after 2026?
According to the Ministry’s announcement, inspections will be conducted regarding the inquiry of temporary or full registration numbers after September 30, 2026. Furthermore, for substances that will be newly manufactured or imported after this date, it will be mandatory to submit a temporary or full registration application before production or importation.
Additionally, it has been announced that for substances that have been temporarily registered, if the necessary data could not be provided during the full registration, an additional period of two years may be granted in addition to the registration deadlines.
This also shows that the Ministry has established a model that is both strict and realistically manages the implementation.
What should companies do now?
At this point, the most accurate approach is to follow this order:
First, the entire product and substance portfolio should be screened on a legal entity basis.
For each substance, tonnage, usage, classification, supply chain role, and OR (single Representative) scope should be determined separately.
Questions should be answered regarding which substances can have a lead registration, which require an individual temporary registration, and which can have a full registration done directly.
KKS data preparations and analytical/technical gaps should be identified immediately.
KDU validation and Turkish document preparations should not be left to the last quarter.
For mixtures, the substance-based registration strategy must be clarified.
Please contact us for full "Kkdik 2026 Temporary Registration and Full Registration Guide" support.
How does Doruksistem provide support?
As Doruksistem, we view this process not only as data entry for KKS under the KKDİK framework but also as a key element for commercial continuity and regulatory security in the Turkish market.
Our support topics include:
KKDİK scope and portfolio analysis
Substance-based registration strategy
Only Representation planning
Coordination of leading companies and joint registrations
Design of individual temporary registration scenarios
Preparation of KKS dossiers.
Analytical and technical data gap analysis
KDU-supported content verification,
Full registration roadmap for 2026 / 2028 / 2030
Only Representative change coordination
In addition to providing strategic and technical support at all stages of the KKDİK registration processes, we offer professional assistance in preparing full and temporary registration files, entering data into KKS, submitting registrations, and post-registration follow-up and monitoring.
You can contact us for detailed information and the support services we provide. Our experts will assist you with all your needs.
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