What Happens in KKDİK After 31 October 2025?

The Next Phase of KKDIK Registration Explained

Under the Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals (KKDIK), the pre-MBDF registration period officially ended on 31 October 2025.

This date marks a turning point for all manufacturers and importers of chemicals in Türkiye, signaling the transition into the next and decisive phase of the KKDIK registration process.

So, what happens next?

Here’s what manufacturers, importers, and non-Turkish producers need to know.

1. What Does the End of the Pre-MBDF Period Mean?

According to Article 6 of the Implementation Procedures and Principles (P&P), all potential registrants were required to submit their pre-MBDF notifications through the Chemical Registration System (KKS) by 31 October 2025 .

This step ensured that:

• Companies declaring the same substance have now become MBDF participants,

• Official MBDF structures are being formed,

• The process for selecting a Lead Registrant has begun.

After 31 October 2025, any new substance placed on the Turkish market must have its pre-MBDF notification submitted within 30 days of the first manufacture or import.

However, the pre-MBDF registration system remains open. You can contact us for detailed information and support.

2. Lead Registrant Selection (Deadline: 31 December 2025)

As defined in Article 8 of P&P, the Lead Registrant for existing substances placed on the market must be determined no later than 31 December 2025 .

For newly marketed substances, the leader must be chosen within six months following market placement.

Key rules:

• Priority is given to voluntary candidates,

• If no volunteer steps forward, the Ministry of Environment, together with TOBB (Union of Chambers and Commodity Exchanges of Türkiye), will appoint a company based on criteria such as tonnage band, available data, and company size,

• The majority approval of MBDF/SIEF members is required to confirm the Lead Registrant.

The Lead Registrant coordinates MBDF communication, performs data gap analysis, and prepares the Joint Submission Agreement.

Once approved by the majority of members, the Lead Registrant may begin the registration process.

3. Joint Submission Groups and the Role of TOBB

Under Article 9 of KKDİK Procedures & Principles (P&P), companies registering the same substance must form a Joint Submission Group (JSG) .

These groups coordinate MBDF operations, manage data sharing, and prepare the technical dossier.

TOBB plays a facilitative role by:

• Supporting the effective operation of Joint Submission Groups,

• Preparing model contracts and guidelines,

• Reporting annually to the Ministry on progress and coordination.

These reports are reviewed during the Chemicals Advisory Board meetings led by the Ministry.

4. The Provisional Registration Period (Until 31 March 2026)

The next critical phase is Provisional Registration.

According to Article 10 of P&P:

• The Lead Registrant must submit the data listed in Annex I via KKS by 31 March 2026 if the full registration dossier cannot yet be completed.

• Member companies (Co-Registrants) must submit their own registration entries by 30 September 2026 following the leader’s submission .

• All data entries must be made by a Certified Chemical Assessment Specialist (KDU), whose credentials must be attached.

• Registration fees set by the Ministry’s revolving fund schedule apply at this stage as well.

• Provisional registrations should be done for all tonnage bands  until the specified dates.

The Annex I of P&P requirements include:

Information requirements for Provisional Registration of Leading Companies, Member Companies and Individual Registration Companies and section numbers in the Chemical Registration System (KKS):

1. Substance Identification (KKS Section 1.1)

1.1 Substance Composition (KKS Section 1.2)

1.2 Analytical Information (KKS Section 1.4)

1.3 Suppliers: In this section, companies enter the names of their company's subusers and keep this information up-to-date. This update is free of charge. (KKS Section 1.7)

1.4 Joint submission (KKS Section 1.5)

2. Globally harmonized System (KKS Section 2.1)

3. Manufacturing, use, exposure information (KKS Section 3)

3.1 Estimated Quantities (KKS Section 3.2)

3.2 Facilities (KKS Section 3.3)

3.3 Information on mixtures (KKS Section 3.4)

3.4 Information on use and exposure (Section 3.5 of the KKS)

3.5 Not Recommended Uses (KKS Section 3.6)

4. Physical and Chemical Properties (KKS Chapter 4)

5. Safe Use Guide (KKS Chapter 11)

Note: Member Companies enter the above-mentioned information requirements 1 and 3 in the relevant sections of the KKS.

This data is uploaded into the modular KKS system, aligned with IUCLID structure.

5. Full Registration Timeline (2026 – 2030)

As defined in Article 11 of P&P, the full registration process will be completed in stages based on tonnage bands :

≥ 1000 t/year and high-risk substances : 31 December 2026

100 – 1000 t/year : 31 December 2028

1 – 100 t/year : 31 December 2030

If a registrant cannot obtain all required data, a justified request for an extension may be submitted through KKS.

The Ministry may grant an additional period of up to two years, except for substances with the 2030 deadline — for which no extensions will be allowed.

6. Who Is Responsible?

Non-Turkish Manufacturers

• All non-Turkish producers exporting to Türkiye must appoint a Turkey-based Only Representative (OR).

• The OR manages MBDF participation and all registration steps on behalf of the foreign entity.

Importers

• If the foreign manufacturer has not appointed an OR, importers become the direct registrants.

• They must join the MBDF and submit their own provisional or full registrations.

Turkish Manufacturers

• Domestic producers are also obliged to register their substances according to tonnage and use.

• Participation in MBDF, data sharing, and dossier updates are mandatory.

The monitoring of MBDF management is directly related to the correct selection of a Only Representative or consultant. Incorrect guidance can lead to high costs and loss of time later on. You can contact Doruksistem for the right strategy and management support in MBDF management.

7. Doruksistem’s Role: Ensuring Compliance Through Expertise

Doruksistem provides end-to-end KKDIK registration and Only Representative (OR) services for manufacturers, importers, and foreign suppliers.

Our expertise includes:

• MBDF participation and Lead Registrant coordination,

• Joint Submission Agreement and dossier management,

• IUCLID/KKS data entry and SDS & SEA notifications,

• KDU-supported provisional and full registration preparation,

• Continuous liaison with TOBB and the Ministry of Environment.

With its digital infrastructure and 20 years of regulatory experience, Doruksistem ensures that your registration process is accurate, traceable, and fully compliant with Turkish and EU requirements.

8. Conclusion

The end of the pre-MBDF period on 31 October 2025 marks not the end — but the beginning — of Türkiye’s full-scale KKDIK implementation.

The focus now shifts to data sharing, leadership organization, and dossier submission.

For companies, this is the moment to align with EU REACH standards and ensure long-term market continuity in Türkiye.

Doruksistem continues to guide all stakeholders through this transition, providing technical, regulatory, and strategic support at every stage.

Please do not hesitate to contact for further information you need or questions you have.