KKDIK Registration Processes Officially Launched: Ministry Announcement and Expert Explanation
- Admin
- 2 days ago
- 5 min read
KKDIK Registration Processes Officially Launched
The recent announcement by the Ministry of Environment, Urbanization, and Climate Change marks a significant shift in the KKDIK registration processes. It introduces a more structured approach to chemical registration and requires companies to adopt a proactive strategy to comply with the new regulatory framework.
This announcement represents a major transition within the KKDIK system, signaling the start of a more organized and clearly defined registration methodology. It underscores the necessity for companies to prepare early and adjust their compliance processes to meet these updated requirements.
Under the KKDIK Regulation, a critical phase has now begun for chemical registration activities. The Ministry’s announcement officially confirms the activation of the Registration module within the KKS system, indicating that companies must now initiate both provisional and full registration procedures. Below, you will find the complete announcement text along with a detailed expert analysis prepared by Doruksistem.
Full Text of the Ministry Announcement (KKDIK Registration Process)
Fully understanding all the details of the KKDIK registration processes is critically important for companies. This includes grasping the nuances of the regulations, following the designated compliance timelines, and recognizing the importance of collaboration among firms to meet registration requirements efficiently.
The full text is provided below.
ANNOUNCEMENT REGARDING KKDIK REGISTRATION PROCESSES
The “Registration” module under the “Substance Management” section of the KKS (Chemical Registration System) has been activated.
1 — In order to submit registrations under the KKDIK Regulation and the “Procedures and Principles for the Implementation of the KKDIK Regulation,” the following steps must be completed:
a) Completion of Pre-MBDF (Pre-SIEF) submissionsb) Establishment of MBDF communication for each substance and election of Lead Registrantsc) Preparation of a comprehensive Agreement between Lead Registrants and potential registrants regarding the fulfilment of joint submission obligationsd) Execution of the processes regarding “Lead election” (Article 8(3)) and “Agreement” (Article 2 and Article 8(4)) through simple majoritye) Preparation and submission of provisional registration or full registration dossiers
2 — All correspondence related to MBDF communication must be retained and made available upon request by the Ministry. Where communication cannot be carried out through the KKS system, any other communication channel may be used.
3 — Workflow for provisional registrations in KKS:
KKS Left Menu → Substance Management → Topic: Registration → Select Substance → Go to Substance →Template: KKDIK Provisional Registration → Submit Substance →Registration Type: KKDIK Provisional Registration → Joint Submission: Yes → Submit
4 — After the Lead Registrant completes Step 4, a notification is sent to member registrants. Member registrants shall follow the steps below:
KKS Left Menu → Substance Management → Topic: Registration → Select Substance → Go to Substance →Template: KKDIK Provisional Registration – Member
5 — Companies wishing to carry out the Provisional Registration individually must:
a) Complete Pre-MBDF submissionsb) Submit a written justification to the Ministry explaining the reason for individual submission (as defined in Article 12(3) of the Regulation)
End of announcement.
You can access the original text (TR Version) of the announcement from this link.
What Does This Announcement Mean for Companies?
(Detailed Expert Explanation on KKDİK Registration Processes)
The activation of the KKS Registration module marks the official start of Türkiye’s KKDIK registration period. This is a critical milestone for manufacturers, importers, Only Representatives, and supply chain stakeholders involved in placing chemical substances on the Turkish market.
Below is a detailed breakdown of the implications of this announcement.
A. KKS Registration Module is Now Fully Operational
The announcement confirms that the system is now ready to accept:
Provisional registration dossiers, and
Full registration dossiers.
This means that all companies placing substances ≥1 tonne/year on the Turkish market must immediately begin preparing their registration files.
The deadlines outlined in the Procedures and Principles (published 05.08.2025) remain in force:
Lead Registrants: Deadline for provisional registration → 31 March 2026
Member Registrants: Deadline for provisional registration → 30 September 2026
B. MBDF Process Becomes a Legally Binding Requirement
According to the Procedures and Principles (Articles 6, 7, 8, 9):
All potential registrants must complete Pre-MBDF submission.
All communication related to MBDF must be documented.
The MBDF serves as the platform where registrants coordinate data-sharing, evaluate existing information, and initiate lead election.
Failure to complete MBDF communication prevents registration.
This aligns KKDIK more closely with EU REACH’s SIEF structure.
C. Lead Registrant Election Must Follow Simple Majority
The Ministry now requires that Lead Registrant election is:
conducted transparently within the MBDF,
based on simple majority voting,
properly documented.
If no voluntary Lead Registrant comes forward, the Ministry—together with TOBB—may intervene to designate a lead candidate.
D. A Comprehensive Joint Submission Agreement Is Mandatory
The announcement highlights the obligation to prepare a Joint Submission Agreement between Lead and member registrants.
This agreement must address:
Data ownership and access rights
LoA (Letter of Access) cost-sharing
Use of IUCLID dossiers
Confidentiality
Rights and responsibilities of each registrant
Leadership and communication procedures
Without this agreement, provisional registration will not be accepted.
E. Provisional Registration Requires Completion of Specific Data Elements
Under Annex 1 of the Procedures and Principles, the following sections must be fully completed:
Substance identity
Composition information
Analytical data
Supplier information
Estimated volumes
Use and exposure information
Facility data
Physical and chemical properties
Safe use instructions
All entries must be submitted by a certified Chemical Assessment Specialist (CAS / KDU).
F. Individual Submissions Require Valid Justification
Companies wishing to submit a registration outside the joint submission must provide:
A written justification based on Article 12(3) of KKDIK
Supporting documentation demonstrating why joint submission is not possible
This is aligned with the EU REACH principle “one substance – one registration.”
For this reason, the period of “unjustified individual registration” has ended.
What Companies Should Do Immediately
We recommend that companies create a clear timeline for their compliance efforts in order to conduct an effective registration process. This timeline should include critical milestones and deadlines to ensure that all requirements are met on time.
To comply with KKDIK and avoid market disruptions, companies should initiate the following steps without delay:
Ensure all substances are pre-registered through Pre-MBDF.
Start MBDF communication and verify substance sameness with other registrants.
Participate in Lead Registrant election.
Conclude the Joint Submission Agreement.
Begin preparing provisional registration dossiers.
Secure a qualified Chemical Assessment Specialist (KDU) for dossier entry.
Decide whether registration will be joint or individual and prepare documentation accordingly.
To effectively manage the registration process, it is crucial for companies to take advantage of specialized consultancy services. Conducting compliance processes under expert supervision and using solutions specifically developed for regulations will significantly reduce administrative burdens while increasing data accuracy and process efficiency.
Additionally, companies must prioritize providing training to their employees on KKDIK regulation and Procedures & Principles. Equipping employees with the necessary knowledge and skills will significantly enhance the organizations’ ability to manage their registration processes more effectively.
Doruksistem’s End-to-End KKDIK Registration Services
Doruksistem provide comprehensive support covering the entire KKDIK process, including:
MBDF management and leadership consultancy
Substance sameness evaluation
Lead Registrant coordination
Preparation of Joint Submission Agreements (LoA/DSA)
IUCLID/KKS technical dossier development
Provisional and full registration dossier submission
KKS data entry by licensed Chemical Assessment Specialists
OR (Only Representative) services for non-Turkish manufacturers
KKDİK KDU trainings, practical application guidance and education
KKDİK management performs completeness checks, audits on your behalf, and reports all processes.
With 20 years of regulatory expertise and advanced digital tools, Doruksistem ensures full compliance with KKDIK, REACH, CLP, and global chemical safety regulations.
“In this context, we provide comprehensive solutions for companies to fulfill all of their obligations under the KKDIK in a timely and accurate manner.”
As Doruksistem, we continue to support and guide companies with our 20 years of experience in dealing with the complexities of the KKDİK registration processes. Our services are not limited to ensuring compliance with regulations; they also include strategic planning and control support to help our clients carry out their registration processes as efficiently as possible.
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