When it comes to chemical management in Turkey, many assume that compliance begins and ends with KKDIK (Registration, Evaluation, Authorization, and Restriction of Chemicals). However, KKDIK is only one piece of a larger regulatory puzzle. Although KKDIK is enforced by the Ministry of Environment, Urbanization, and Climate Change, it intersects with various regulations from other ministries, such as the Ministry of Trade, the Ministry of Health, the Ministry of Agriculture and Forestry, and the Ministry of Industry and Technology.
In recent months, these ministries have introduced and updated several regulations and communiqués that place additional responsibilities on exporters, importers, and other stakeholders.
This blog post will show why “KKDIK: It’s More Than Just KKDIK!” is particularly relevant for international manufacturers and importers aiming to do business in Turkey, and will also highlight the solutions offered by Doruksistem AS.
1. An Overview of KKDIK and Its Wider Impact
What Is KKDIK?
KKDIK is Turkey’s chemical management legislation, closely modeled after the EU’s REACH regulation.
It came into force on June 23, 2017, and as of December 31, 2023, all companies manufacturing or importing more than 1 ton of a chemical per year in Turkey must have completed the relevant registration processes.
KKDIK seeks to protect human health and the environment, imposing obligations related to registration, evaluation, authorization, and restriction on chemical substances.
Why “It’s More Than Just KKDIK”?
KKDIK is comprehensive but does not cover all requirements on its own.
Issues like customs clearance, market surveillance, waste management, product safety, and even food contact materials all require compliance with additional regulations across multiple ministries.
International companies focusing solely on KKDIK risk facing unforeseen penalties, delays, or even import refusals at Turkish customs if they overlook other regulations.
2. Ministry of Trade: New Import Communiqués and the Bigger Compliance Framework
2.1 Product Safety and Technical Regulations Law (No. 7223)
Under the authority of the Ministry of Trade, Law No. 7223 on Product Safety and Technical Regulations regulates the placing of products on the market, labeling, traceability, and inspection.
Even if a chemical (or a chemical-containing product like paint, detergents, adhesives, etc.) meets KKDIK requirements, it must also comply with the technical regulations and labeling requirements mandated by Law No. 7223.
2.2 Market Surveillance and Inspection (MSI) Regulations
The Ministry of Trade manages market surveillance largely through TAREKS (Risk-Based Trade Control System).
Any imported or domestically produced chemical substance may be flagged for risk analysis.
If deemed non-compliant under MSI Regulations, penalties can include fines, product recalls, or destruction.
2.3 Recent Import Inspection Communiqués (December 2024 – January/February 2025)
December 2024 saw new communiqués in the Official Gazette that impose stricter documentary and testing requirements for high-risk chemicals:
“Communiqué on Import Controls of Hazardous Chemicals (2024/xx)”: Revised pre-authorization procedures for certain carcinogenic, mutagenic, or reprotoxic chemicals. Additional toxicological and ecotoxicological test reports may be required during importation.
“Communiqué on Chemical-Based Products’ Import Controls (2024/yy)”: Tightened inspections on finished products (paints, adhesives, cleaning agents, etc.) containing specified chemicals. Risk categories within TAREKS have been broadened.
January–February 2025 updates further require:
Advance notification and extra certification for certain imported chemical products.
A declaration of KKDIK compliance for the chemicals used.
Additional lab tests or analyses at customs.
Proof of relevant ministry approvals (e.g., Ministry of Health or Ministry of Agriculture and Forestry) where applicable.
Failure to align with these communiqués—relying only on KKDIK registration—can lead to delays or refusals at customs.
3. Ministry of Environment, Urbanization, and Climate Change: Beyond KKDIK
3.1 Waste Management and Packaging Legislation
Under the Waste Management Regulation, companies handling hazardous wastes must obtain specific licenses or use authorized facilities for disposal.
Packaging Waste Control Regulation imposes labeling and collection requirements for packaging containing chemicals.
3.2 Climate Change and Green Policies
The chemical industry has a significant carbon footprint. Upcoming Carbon Border Adjustment Mechanisms (CBAM) from the EU may affect Turkish exporters and importers alike.
Under Turkey’s Green Deal Action Plan, future KKDIK registrations might include carbon footprint data or additional sustainability documentation.
4. Ministry of Industry and Technology: Technical Standards and Conformity Assessment
4.1 Industrial Product Safety
Registered chemicals under KKDIK that exhibit flammable, explosive, or toxic properties may be subject to extra precautions under industrial safety regulations (e.g., ATEX, SEVESO).
The Ministry of Industry and Technology oversees these specialized standards.
4.2 Certification Bodies
Certification and conformity assessment bodies must be accredited by the Ministry.
Hazardous or high-risk chemicals may require technical reports or certificates from recognized bodies, such as the Turkish Standards Institution (TSE).
5. Ministry of Health: Cosmetics, Biocides, and Medical Devices
The Ministry of Health enforces regulations on cosmetics, biocidal products, and medical devices that contain chemical substances.
Even if a chemical is fully compliant with KKDIK, it may need additional safety, labeling, and testing procedures under the Ministry’s rules.
Increased demand for hygiene and disinfection products has led to stricter biocidal product authorization.
Important: Biocidal product imports cannot rely solely on KKDIK compliance. A Biocidal Product Registration or a proper authorization under the Ministry of Health is mandatory.
6. Ministry of Agriculture and Forestry: Pesticides, Fertilizers, and Food Contact Materials
Pesticides (crop protection agents) and fertilizers fall under the purview of the Ministry of Agriculture and Forestry. Although they must comply with KKDIK, specific agricultural and environmental checks also apply.
Food contact materials (such as plastic packaging, coatings, or colorants) require safety evaluations on chemical migration into food.
Consequently, any item that comes into contact with food must comply not only with KKDIK but also with the Ministry’s regulations on safety and testing.
7. Upcoming Regulations and Key Considerations
EU Green Deal / Carbon Border Adjustment Mechanism (CBAM)
Potential carbon taxation and mandatory carbon footprint reporting may significantly impact chemical exports.
While KKDIK focuses on chemical hazards, climate-related reporting will soon become a core compliance feature.
Cross-Ministerial Audits
Joint inspections by Trade, Health, Agriculture and Forestry, Environment, and Industry Ministries are increasingly common.
Chemical products undergo a holistic check: from production or import through to storage, labeling, and market distribution.
Digital Transformation and Traceability
TAREKS continues to expand, and integrated data-sharing between ministries is expected to strengthen oversight of high-risk chemicals.
Wider adoption of electronic certification and digital product passports is on the horizon.
Sector-Specific Developments
Additional EU-aligned regulations are underway for cosmetics, cleaning products, pharmaceuticals, medical devices, agricultural chemicals, and paints.
The Ministry of Agriculture and Forestry is ramping up penalties for pesticides and veterinary drugs.
8. Recommendations for International Companies
Create a Cross-Ministerial Compliance Strategy
Review regulations by the Ministry of Trade, Ministry of Health, Ministry of Agriculture and Forestry, Ministry of Environment, and Ministry of Industry—beyond KKDIK alone.
Keep Up with New Communiqués
Monitor the Official Gazette regularly for the latest announcements. High-risk chemicals and biocides face increasingly stringent rules, especially after December 2024 updates.
Work with a Local Representative or Consultant
KKDIK registration requires a Turkey-based representative. Choose a consultancy well-versed in broader regulatory obligations to avoid surprises.
Maintain Updated Technical Documentation
Beyond KKDIK’s SIEF data and testing, you may need toxicology, residue analyses, or other reports demanded by the Ministry of Health or Agriculture and Forestry.
Incorporate Sustainability and Climate Strategies
Preparing for carbon taxes or green certification can be a strategic advantage, especially for exports to the EU.
9. Doruksistem’s Integrated Solutions
Navigating Turkey’s multi-agency regulatory environment requires a holistic approach covering KKDIK and the full spectrum of chemical-related rules. Doruksistem offers:
Regulatory Compliance Analysis & Strategic Consultancy
We integrate the latest regulations from the Ministry of Trade, Health, Agriculture and Forestry, Environment, and Industry into one cohesive compliance roadmap.
Our risk assessment process helps minimize bureaucratic hurdles during import and export.
Authorized Representative Services
We serve as your official representative for KKDIK registration, authorization, and restriction processes.
For biocidal products, cosmetics, and other specialized chemicals, we guide you through the relevant authorization processes with the Ministry of Health and the Ministry of Agriculture and Forestry.
Digital Certification & Traceability: UseSafe
UseSafe by Doruksistem is a Digital Product Certification & Traceability platform that verifies chemical safety and sustainability.
Stakeholders (manufacturers, importers, consumers, and authorities) can access up-to-date product safety information, ensuring transparency and faster audits.
Sustainability, Carbon Reporting, and Future Regulations
We provide proactive planning and reporting solutions for upcoming EU regulations like the Green Deal and carbon border tax.
We integrate carbon footprint calculations and improvement projects in line with the Ministry of Environment, Urbanization, and Climate Change policies.
Ongoing Training and Updates
Doruksistem delivers regular seminars, training sessions, and newsletters covering KKDIK, product safety, biocides, and more.
Your in-house teams will be informed of any new or pending legislative changes, enabling a swift and effective response.
Conclusion
“KKDIK: It’s More Than Just KKDIK!” succinctly captures the multifaceted nature of Turkish chemical regulations. Recent import communiqués (December 2024 – January/February 2025) issued by the Ministry of Trade, combined with biocidal and cosmetic regulations from the Ministry of Health, stringent pesticide rules from the Ministry of Agriculture and Forestry, and industrial safety requirements from the Ministry of Industry and Technology, form a complex regulatory ecosystem.
At Doruksistem, we provide comprehensive consultancy, representation, and digital certification services to help you navigate these regulations with minimal risk and maximum efficiency.
Remember, KKDIK compliance is critical but not all-encompassing: regulatory obligations across customs, waste management, biocides, food contact materials, and product safety are equally crucial for success in Turkey. By adopting an integrated, multi-ministry compliance strategy, international firms can operate smoothly and sustainably within this dynamic market.
Comments