KKDİK 2026 Temporary Registration and Full Registration Guide

Following the announcement from the Ministry on March 6, 2026, companies need to clarify their registration strategies without delay as part of the establishment of Turkey’s chemicals inventory.

The ministry’s announcement dated March 6, 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.

New Developments in the Creation of the Türkiye Chemicals Inventory

An important development has taken place in Turkey regarding the registration processes of chemical substances under the Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals (KKDİK). With the recent announcements made by the Ministry of Environment, Urbanization and Climate Change, a new transition period application has been initiated to ensure that KKDİK registration processes are conducted more swiftly and effectively.

The main aim of this regulation is to systematically identify the chemical substances offered on the market in Turkey and to create a Turkish Chemicals Inventory. This inventory is intended to provide traceability for chemical substances produced or imported in Turkey, thereby aiming to establish a stronger chemical management system in terms of both environmental and human health.

Under the new announcements, companies that are obligated to register under the KKDİK regulation must obtain their full registration or temporary registration numbers by September 30, 2026.

This article provides a detailed explanation in line with the recent announcements published under KKDİK regarding:

The purpose of creating the Turkish chemicals inventory
New developments in KKDİK registration processes
The individual temporary registration mechanism
New opportunities introduced for MBDF structures
The registration process roadmap for companies

Importance of the Türkiye Chemicals Inventory

The management of chemicals has become a critical component of modern environmental, public health and sustainability policies.

The establishment of the Türkiye Chemicals Inventory aims to:

identify all chemical substances placed on the Turkish market
strengthen chemical risk management practices
improve traceability of substances across the supply chain
further align Türkiye’s chemical regulatory framework with the EU REACH Regulation.

For this reason, the Ministry has introduced new measures to ensure that all substances placed on the market are properly registered within the national chemical registration system.

Transitional Phase in the KKDIK Registration Process

Türkiye is currently in a temporary phase aimed at preparing the regulatory system for the full implementation of substance registration under the KKDIK Regulation.

By the end of this temporary period, companies placing chemical substances on the Turkish market must hold one of the following registration numbers:

Full registration number
Provisional/Temporary Lead registration number
Provisional/Temporary Member registration number
Provisional/Temporary Individual registration number

All of these registration procedures must be completed regardless of tonnage by 30 September 2026.

This requirement ensures that every chemical substance present in the Turkish market will be recorded within the national system.

Procedures and Principles (P&P) and New Regulation August 5, 2025

The Procedures and Principles published on 05 August 2025 established the operational framework for provisional registrations.

Under those procedures, separate deadlines had been defined for:

lead provisional registrations
member provisional registrations.

However, according to the latest announcement issued by the Ministry, these deadlines have now been harmonized under a single deadline.

As a result, the final deadline for both lead and member provisional registrations has been redefined as 30 September 2026.

This regulatory update aims to simplify the registration process and ensure smoother implementation across the industry

What is Temporary Individual Registration?

One of the most important regulatory developments introduced by the recent announcement is the expansion of the temporary individual registration mechanism.

Temporary individual registration allows companies to submit provisional registration dossiers independently, even if the joint registration process within their Substance Information Exchange Forum (MBDF) has not yet been completed.

Companies may submit temporary individual registrations when there are legitimate reasons such as:

disproportionate cost sharing arrangements
confidentiality concerns regarding data
disagreements related to data selection
technical or commercial disputes among MBDF members.

In such cases, companies may submit their justification through the Chemical Registration System (KKS) and proceed with temporary individual registration.

Which MBDF Structures Are Affected by This Regulation?

The newly introduced temporary individual registration option applies to several different MBDF scenarios.

Substances with a Lead Registrant who has already submitted a full registration dossier

Member companies participating in the MBDF may still submit temporary individual registrations if they have justified reasons.

MBDF groups where a Lead Registrant has been identified but the registration dossier has not yet been submitted

In such cases, MBDF members are also entitled to submit temporary individual registrations.

MBDF groups where no Lead Registrant has been identified

Temporary individual provisional registration is also available for substances where a Lead Registrant has not yet been appointed.

This regulatory flexibility has been introduced in order to address the challenges experienced by the industry in appointing Lead Registrants.

Update to the Temporary Lead Registration Process

The provisional/temporary leader registration process has been updated with the new regulation.

The previously set temporary leader registration deadline of March 30, 2026, has been extended to September 30, 2026, with the new regulation.

This extension allows MBDF members to complete their provisional member registrations by the same deadline once a temporary Lead Registrant has been appointed.

Submission of Temporary Registration with Missing Information

Preparing registration dossiers may require time, particularly when generating technical data.

Therefore, the regulation introduces additional flexibility.

If certain information required under Annex-1 of the Procedures and Principles cannot be obtained in time, companies may still submit temporary registration dossiers by providing documented justification through the Chemical Registration System.

The missing information can later be updated in the system before the final registration deadlines.

Important Note for Companies Holding Full Registration Numbers

Companies that already obtained a full registration number for a substance are not required to obtain a temporary/provisional registration number for the same substance.

Additional Time for Completion of Full Registration Dossier

If the necessary data required for full registration cannot be generated within the standard deadlines, an additional two-year extension may be granted.

During this extension period, the generation of missing data and the completion of registration dossiers will be monitored through meetings of the Chemicals Consultation Group.

Recommended Roadmap for Companies

It is recommended for companies to follow the steps below:

Identify the imported or domestically manufactured substances.
Check whether the imported substances have an appointed Only Representative by communicating with the foreign manufacturers. If appointed, has the importer been added as a supplier? (If not appointed, it is important for the importer to evaluate their registration responsibilities.)
Check the MBDF status. (It should not be forgotten that a pre-MBDF is required to check the MBDF status.)
Evaluate the status of the leading company.
If necessary, make an temporary individual registration.
Initiate the MBDF communication and preparation process for full registration.

Frequently Asked Questions (FAQ)

What substances are subject to registration under KKDIK?

Chemical substances manufactured in or imported into Türkiye in quantities of 1 tonne or more per year are subject to registration under the KKDIK Regulation.

Is individual provisional registration mandatory?

Temporary individual registration is not mandatory for all companies. However, it provides an important mechanism for companies that cannot complete the joint registration process within their MBDF.

What happens if registration is not completed by 30 September 2026?

After September 30, 2026, the complete registration, temporary registration, or temporary individual registration numbers of the substances manufactured or imported by companies will be audited. Pre-MBDF registration numbers will not be considered as registration numbers. Substances offered to the market without registration number (Complete Registration, Temporary Registration, or Temporary Individual Registration) will be deemed in violation of the regulations.

Does temporary registration replace full registration?

No. Provisional registration is a temporary mechanism intended to facilitate the transition toward full registration.

Do companies with a full registration number need to submit provisional registration?

No. Companies that have already obtained a full registration number do not need to apply for temporary registration for the same substance.

Conclusion

New announcements published within the scope of KKDİK aim to accelerate Turkey’s transition to the full registration phase of the chemical substance registration system.

It is crucial for companies to obtain the necessary registration (full registration, temporary registration, or temporary individual registration) numbers by September 30, 2026, to complete the creation of Turkey’s chemical inventory and registration processes.

Companies that prepare early will be able to manage both data sharing and registration processes more effectively.

You can follow developments through the Chemicals Help Desk.

“KKDİK 2026 Process: What Needs to Be Done for Individual Temporary Registration or Full Registration by September 30, 2026“

You can visit our page to access the original text of the announcement and obtain more detailed information on the topic.

Need Support with KKDIK Registration?

The KKDIK Regulation introduces key obligations for companies manufacturing or importing chemicals into Türkiye. Understanding requirements for temporary registrations, MBDF participation, and full registration can be complex for exporters to the Turkish market.Doruksistem offers regulatory compliance services to help you navigate the KKDIK process effectively. Our services include:• KKDIK registration strategy and assessment • Lead Registrant and MBDF coordination • Provisional/Temporary registration submissions • Full registration dossier preparation • Only Representative services for non-Turkish manufacturers • Safety Data Sheet preparation and reviewWith over 20 years of experience, Doruksistem helps international manufacturers meet their chemical regulatory obligations in Türkiye.If your company exports chemicals to Türkiye or plans to enter the Turkish market, our experts are ready to assist.👉 Contact our KKDIK experts today to discuss your strategy.

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KKDİK 2026 Temporary Registration and Full Registration Guide: What Needs to be Known?

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 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 6, 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.

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

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.

KKDIK 2026 Temporary Registration and Full Registration Guide