Understanding KKDIK Procedures and Principles (2025) – Complete Guide for Chemical Compliance in Türkiye

Admin
Oct 9
5 min read

What Is KKDIK (Turkish REACH)?

KKDIK (Registration, Evaluation, Authorization, and Restriction of Chemicals) is Türkiye’s national chemical regulation aligned with the EU REACH Regulation (EC 1907/2006).

The new Procedures and Principles, published on August 5, 2025, provide a detailed framework for registration, data sharing, evaluation, and compliance monitoring.

👉 Read the full guide on Doruksistem.com.tr

Key Updates in the 2025 KKDIK Procedures and Principles

Broader Scope of Application
The Procedures and Principles define the overall framework for implementing the Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals. They cover administrative, technical, and procedural matters related to chemical registration, evaluation, authorization, restriction, and integrated chemicals management — including the responsibilities of all actors, data submission processes, and coordination between relevant authorities.
Registration
The KKDİK Procedures and Principles define the detailed process for registering chemical substances manufactured or imported into Türkiye. They explain how companies must submit registration files to the Chemical Registration System (KKS), what data must be included, and how registration coordination works between companies that handle the same substance. The process includes pre-MBDF notifications, participation in MBDF groups, selection of a Lead Registrant, and submission of a joint or individual registration dossier. It also introduces provisional registration, allowing companies to maintain market access while completing missing data, and requires registrants to update any change in composition, use, or tonnage within three months. This framework ensures traceable, transparent, and harmonized chemical registration under KKDIK.
Mandatory Pre-MBDF Registration
Companies (Manufacturers, Importers, Only Representatives) must submit a pre-MBDF (pre-SIEF) Registration via the KKS (Chemical Registration System) before full registration. This step enables communication and data sharing between registrants handling the same substance. Non-submission may lead to exclusion from MBDF participation. SEA notifications should be submitted before pre-MBDF registrations.
MBDF (Substance Information Exchange Forum) Structure
MBDFs are now formalized with clear rules for governance, record-keeping, cost sharing, and data exchange. Each MBDF must maintain transparent records of internal agreements, available for audit by the Ministry of Environment, Urbanization, and Climate Change (MoEUCC).
Lead Registrant (LR) Role and Responsibilities
The Lead Registrant plays a crucial coordinating role — responsible for the technical dossier, Chemical Safety Report (CSR), and hazard classification under the SEA Regulation.
In cases where no volunteer emerges, the Ministry may appoint a Lead Registrant based on technical capacity, tonnage bands, or prior REACH experience.
Joint Registration Group (JRG) and Fair Cost Sharing
The new Joint Registration Group (JRG) model promotes cooperation between MBDF members for joint dossier preparation.
Members must adhere to transparent data sharing and cost-sharing principles, consistent with Article 27 of EU REACH, preventing duplication of tests and promoting fair access.
Provisional Registration & Extended Deadlines
To ensure business continuity, provisional registration is now allowed:
- Lead Registrant provisional dossier: due by 31 March 2026
- Member dossiers: due by 30 September 2026
  Provisional registrations remain valid until full submissions are completed, granting flexibility while maintaining compliance integrity.
Advisory & Scientific Committees (CSG / CAG)
Two expert panels — the Chemical Science Group (CSG) and the Consultative Advisory Group (CAG) — will assist the Ministry in evaluating technical and policy issues. These committees contribute to future restriction decisions, exemption evaluations, and new test method guidance.
Integration with Other Turkish Regulations
KKDIK now interlinks with the SEA (TR-CLP) – By-Law on Classification, Labelling and Packaging of Substances and Mixtures, KOK (TR-POP) – Regulation on Persistent Organic Pollutants, e-PIC – Regulation on the Export and Import of Certain Hazardous Chemicals, MERCURY (upcoming), etc.).regulations, ensuring unified data management, labeling alignment, and traceability across chemical, biocidal, and product safety frameworks.
Ongoing Registration Maintenance
Any updates in tonnage, use category, or chemical composition must be reported in the KKS within three months. This requirement supports lifecycle traceability and consistency with international data systems.
Digitalization and Traceability
The Procedures introduce full digital submission through KKS, including electronic signatures, audit trails, and system interoperability.
These advancements prepare the regulatory infrastructure for future integration with Digital Product Passports (DPP) and blockchain-based traceability tools.

New SDS (Safety Data Sheet) Requirements under KKDIK

The 2025 KKDIK Procedures and Principles introduced stronger obligations for Safety Data Sheets (SDS), reinforcing product safety and downstream communication.

SDS Language and Format
- All SDS must be written in Turkish, compliant with Annex II of KKDİK and SEA Regulation.
- Each sheet must include 16 sections, covering identification, hazards, composition, first aid, firefighting, handling, exposure controls, transport, and disposal.
Certified Authors (KDU Requirement)
SDSs must be prepared or verified by a Certified Chemical Assessment Specialist (KDU) approved by the Ministry. Non-certified SDSs are considered invalid under KKDIK.
SDS Portal Submission Requirement
Under the new Procedures, all finalized SDSs must be uploaded to the Ministry’s official SDS Portal (SDS Portal of MoEUCC) for registration, validation, and inspection purposes by KDUs. The portal ensures traceability, version control, and transparency between suppliers, importers, and authorities.
When SDS Is Required
- For all hazardous substances and mixtures.
- For non-hazardous mixtures containing certain concentrations of classified substances.
- Upon first supply or any revision of classification, composition, or labeling.
Updating and Distribution
- Updates are mandatory whenever new data on hazards or control measures become available.
- Updated SDSs must be provided free of charge to all downstream users within three months.
SEA / CLP Consistency
The classification and labeling in the SDS must match SEA notifications.
Doruksistem ensures complete alignment across KKDIK registration data, SEA labels, and SDS content.

Why SDS Compliance Matters

SDSs are legally required for product safety communication under KKDIK.
Incorrect or missing SDS uploads may result in fines or suspension of market access. Non-compliant SDSs can lead to market withdrawal or penalties.
Consistent SDS and SEA data are essential for inspection readiness and supply chain trust.
Consistent SDSs build trust in your supply chain and demonstrate due diligence during inspections.
Downstream users rely on accurate SDSs to ensure workplace and consumer safety.
Proper SDS management supports ESG, sustainability, and traceability goals within the TR Green Deal framework.

Why KKDIK Compliance Matters

Non-registered substances cannot be legally marketed in Türkiye
Non-compliance may lead to penalties or sales restrictions
Missing pre-registrations cause supply chain disruptions
The Ministry cross-checks imports against KKDIK registration records

Compliance is therefore a strategic business requirement, not only a legal one.

Doruksistem – Your Trusted Partner for KKDIK / TURKREACH Compliance

As one of Türkiye’s leading regulatory consultancy firms, Doruksistem A.Ş. provides expert support for all KKDIK, SEA, and CLP compliance activities, offering integrated digital and technical solutions.

Our Specialized KKDIK Services

KKDIK Registration Management – dossier preparation, pre-registration, and communication with the MoEUCC
Only Representative (OR) Service – full legal representation for non-Turkish manufacturers
MBDF & Lead Registrant Coordination – negotiation, agreement drafting, and cost-sharing facilitation
SEA Notification & CLP Alignment – labeling, hazard communication, and PCN preparation
SDS Authoring & Validation – compliant Safety Data Sheets (SDS) and classification under SEA Regulation. Doruksistem provides certified SDS authoring, validation, and SDS Portal submission services to ensure full legal compliance.
Regulatory Audits & Gap Analysis – dossier review, correction, and ministry audit readiness
Training & Continuous Monitoring – on-site and remote compliance workshops for technical teams

Doruksistem also integrates AI-based compliance tools and UseSafe® Digital Product Certification to help clients maintain sustainable and transparent supply chains.