News Details

The Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) has issued an announcement requiring all chemical manufacturers and importers operating in Turkey to submit their transitional registration dossiers under the Chemicals Registration System (KKDIK) by September 30, 2026.

This updated guidance marks a significant shift in KKDIK compliance expectations. Under the new framework, all potential registrants—whether acting as individual registrants, lead registrants, or members—must now complete their transitional registrations within the specified timeframe. The announcement does not discriminate tonnage band and registrant role distinctions, meaning companies affected by different registration deadlines depending on their tonnage band or lead registrant availability of their substance must now submit a transitional dossier rather than waiting.

The MoEUCC emphasizes that establishing a comprehensive chemicals inventory is critical for national regulatory compliance. Companies are advised to review their chemical portfolios and prepare accordingly. The September 30, 2026 deadline applies to all registrants, and submission must be completed through the official Chemicals Registration System (KKS) portal.

Implementation Resources

The Ministry has made available step-by-step guidance materials for companies navigating this transition. Flowchart documentation and instructional videos on KKS portal navigation are accessible via the Chemicals Help Desk section of the Ministry's website. These resources outline the process for individual transitional registration submissions, including how member firms should enter data into the KKS system.

Strategic Implications for Industry

This directive represents a substantial change in KKDIK compliance expectations across the Turkish chemical industry. With this update, the Ministry seems to spark the collective action towards full compliance, perhaps starting with smaller initial achievements, and to have a clear picture of number of registrants for each substance as well as number of substances to be registered. This initial momentum is expected to put the industry into motion towards timely KKDIK-compliance.

Ambiguities

Several questions remain regarding the implication of this new guidance that are contradicting with the communiqué on “Procedures and Principles” published on August 2025; such as “one-substance-one-registration” rule. Unclarity regarding the next actions of SIEF members of a substance that already has a lead registrant and a registered complete joint submission dossier but lacking data-sharing workflows and letter of access purchase details is one of the biggest questions that beg clarification from the authorities.