Updated Guidance Following the Ministry Announcement Dated 06 March 2026

1. What is KKDIK Individual Interim Registration?

KKDIK Individual Interim Registration is a temporary registration pathway introduced for chemical substances whose full KKDIK registration process has not yet been completed.

In simple terms, a company may wish to place a chemical substance on the Turkish market while the full registration process is still ongoing. Following the Ministry announcement published on 06 March 2026, the Individual Interim Registration mechanism may allow companies to continue the process under certain conditions.

This system is generally considered a transitional solution intended to prevent registration activities from coming to a complete stop while full compliance procedures continue.

KKDIK Individual Interim Registration

2. Is it possible to complete KKDIK interim registration without LoA?

Yes. This is currently one of the most discussed topics regarding the new process.

Under standard full registration procedures, data sharing, consortium participation, and Letter of Access (LoA) requirements can create significant costs for companies. In particular, small and medium-sized businesses often face difficulties due to high LoA expenses.

According to the announcement published on 06 March 2026, LoA is not required at the Individual Interim Registration stage.

For this reason, the interim registration process may provide an important alternative solution for companies whose KKDIK activities were delayed due to LoA-related issues.

KKDIK Individual Interim Registration

3. Does KKDIK Individual Interim Registration replace full registration?

No, it does not.

Individual Interim Registration should not be considered equivalent to a full KKDIK registration.

A simple way to understand the difference is this: interim registration is a temporary pathway designed to keep the process moving, whereas full registration remains the final regulatory obligation under KKDIK.

Therefore, companies should not assume that “everything is completed” once interim registration is submitted. Substance management, tonnage evaluations, use information, and future compliance obligations must still be monitored carefully.

KKDIK Individual Interim Registration

4. Are foreign companies exporting chemicals to Turkey affected by this process?

Yes, they may be affected.

Manufacturers exporting chemical substances to Turkey from countries such as Germany, the United Kingdom, France, Italy, China, and India should carefully evaluate their current KKDIK status.

Exporting chemicals to Turkey is not only a commercial activity; it may also create regulatory obligations under Turkish chemical legislation.

Many foreign manufacturers assume that having an EU REACH registration is automatically sufficient for Turkey. However, this is not correct. KKDIK is a separate Turkish regulation and must be assessed independently.

KKDIK Individual Interim Registration

5. If a company already has EU REACH registration, is KKDIK still required?

Yes.

Having an EU REACH registration can provide important advantages, but it does not automatically eliminate KKDIK obligations in Turkey.

EU REACH is a European Union regulation, while KKDIK is the Turkish chemical registration regulation.

In other words, a substance registered under EU REACH is not automatically considered registered under KKDIK.

However, existing EU REACH technical data may support certain parts of the KKDIK process, which can make technical preparations easier for some companies.

KKDIK Individual Interim Registration

6. Is KKDIK interim registration performed for products or for substances?

KKDIK registration is performed for substances, not for products.

This is one of the most misunderstood topics.

For example, a company may have 10 different products containing the same chemical substance with the same CAS number. In such cases, the evaluation is not made product by product, but based on the total tonnage of that substance.

The key question is not:
“How many products are imported?”

The key question is:
“How many tons of this specific CAS substance are placed on the Turkish market annually?”

For this reason, a product list alone is not sufficient during KKDIK evaluations. Substance content and annual tonnage calculations must also be reviewed carefully.

KKDIK Individual Interim Registration

7. How is tonnage calculated for mixtures under KKDIK?

For mixtures, each chemical substance must be evaluated separately.

For example, a company may import 100 tons of a mixture per year. If one substance is present at 10% concentration, the tonnage for that substance would be calculated as 10 tons annually.

If the same substance also exists in other imported products, all quantities must be added together.

In simple terms:

Annual product quantity × substance concentration = annual tonnage for that CAS substance

Therefore, stating only the total product quantity is not sufficient. The concentration and total annual amount of each substance are also critical.

KKDIK Individual Interim Registration

8. Why is pre-SIEF / pre-MBDF control important?

Before starting the interim registration process, the current status of the substance should be checked carefully.

In some cases:

• a previous pre-registration may already exist,
• the registration may have been submitted by another representative,
• the registration may be inactive,
• or the process may have been initiated under an incorrect CAS number.

For this reason, one of the first steps should always be verifying the current pre-SIEF / pre-MBDF status.

Starting the process without these checks may lead to delays and technical problems later.

KKDIK Individual Interim Registration

9. What happens if KKDIK interim registration is not completed?

The consequences depend on the company’s current regulatory status. However, if a substance falls within the scope of KKDIK and the required actions are not managed properly, problems may arise during importation, supply, or market placement activities in Turkey.

Simply put:
If a substance is imported, sold, or supplied in Turkey, its KKDIK status should be evaluated carefully.

Ignoring the registration process completely may create risks related to supply chains, customs, commercial operations, and regulatory inspections.

KKDIK Individual Interim Registration

10. When should companies start the KKDIK interim registration process?

The earlier, the better.

The process involves much more than simply submitting forms. Companies should first evaluate:

• substance lists,
• CAS numbers,
• annual tonnage ranges,
• current registration status,
• OR structures,
• technical data availability,
• and KKS system requirements.

In addition, Ministry completeness checks and possible technical revision requests may also require additional time.

For this reason, waiting until the final period may create serious risks, especially for companies managing multiple substances, mixtures, or different tonnage bands.

KKDIK Individual Interim Registration

11. Is there a deadline for KKDIK Individual Interim Registration?

Yes.

One of the most researched topics following the announcement dated 06 March 2026 is the deadline.

Many companies are currently trying to understand how long the process will remain available, when action should be taken, and what may happen if the process is delayed.

Especially for companies managing multiple CAS numbers, the process may require time due to:

• tonnage calculations,
• data collection,
• system entries,
• and current registration status checks.

For this reason, it is important to complete the technical preparation process without waiting until the last period.

KKDIK Individual Interim Registration

12. What information is required for KKDIK interim registration?

Companies should first prepare the following basic information:

• CAS numbers,
• annual tonnage amounts,
• product compositions,
• importer information,
• manufacturer information,
• current pre-SIEF / pre-MBDF status,
• and existing EU REACH information, if available.

Many companies assume that providing only the product name is sufficient. However, KKDIK evaluations are not performed based on product names, but on chemical substance information.

For this reason, technical composition details are critically important.

KKDIK Individual Interim Registration

13. Is KKDIK registration required for every chemical product?

No.

Not every product automatically falls within the registration scope. First, the following should be evaluated:

• the substance status under KKDIK,
• annual tonnage,
• use conditions,
• and import structure.

Some substances may fall under exemptions, while others may require registration obligations.

For this reason, each product may require separate technical evaluation.

KKDIK Individual Interim Registration

14. What happens if the same substance is imported by multiple companies?

This situation is very common within KKDIK processes.

The same substance with the same CAS number may be imported into Turkey by different importers. However, each company’s import quantity, use conditions, and registration status are evaluated separately.

In some cases, companies may participate in:

• the same data-sharing processes,
• the same consortium structures,
• or similar technical studies.

For this reason, the current registration structure should be reviewed carefully from a technical perspective.

KKDIK Individual Interim Registration

15. Are laboratory tests required for KKDIK interim registration?

This may vary depending on the substance, existing data availability, and technical dossier structure.

Some companies already possess technical data under EU REACH, while in other cases additional data requirements may arise.

For this reason, it would not be correct to say:
“Every substance definitely requires new testing”
or
“No testing is ever required.”

Each substance should be evaluated individually from a technical perspective.

KKDIK Individual Interim Registration

16. What is the KKS system?

KKS, meaning the Chemicals Registration System, is the official platform used for KKDIK processes.

Applications, company information, tonnage entries, and technical procedures are managed through this system.

Incorrect system entries may lead to:

• process delays,
• technical errors,
• or incomplete submissions.

For this reason, system operations should be managed carefully.

KKDIK Individual Interim Registration

17. What is an OR (Only Representative)?

An Only Representative (OR) is a representative structure that may manage certain KKDIK processes in Turkey on behalf of manufacturers located outside Turkey.

In particular, foreign manufacturers may prefer to work through an OR structure in order to manage Turkish import processes more efficiently.

However, since every company structure is different, the following should also be evaluated separately:

• current import model,
• distributor structure,
• and registration history.
• KKDIK Individual Interim Registration

18. Is it possible to change the OR (Only Representative)?

Yes, in some cases it is possible.

However, the following should first be reviewed technically:

• existing pre-SIEF registrations,
• active processes,
• system matches,
• and previous representative structures.

In particular, initiating changes without clarifying which company currently manages the registrations may create problems later.

KKDIK Individual Interim Registration

19. Why do KKDIK interim registration costs vary?

Because every company structure is different.

The main factors affecting costs may include:

• number of CAS substances,
• tonnage bands,
• data availability,
• current registration structure,
• technical study requirements,
• and consultancy scope.

For this reason, the same cost structure does not apply to every company.

KKDIK Individual Interim Registration

20. What is the biggest mistake companies are currently making?

The biggest mistake is leaving the process until the last minute and evaluating substances only based on product names.

However, within KKDIK processes:

• CAS-based analysis,
• tonnage calculations,
• current registration checks,
• and technical data evaluations

are critically important.

Many companies attempt to proceed only with product lists and later encounter serious technical problems during the process.

Why Should Companies Choose Kavi Consultancy for KKDIK Processes?

Experience in Active KKDIK Registration Processes

KKDIK compliance is not only about theoretical regulatory knowledge.
Many companies face practical challenges related to:

• LoA processes,
• pre-SIEF controls,
• tonnage calculations,
• KKS system procedures,
• OR structures,
• and technical registration management.

Kavi Consultancy actively supports ongoing KKDIK projects and follows current Ministry procedures closely.

Support for International Manufacturers Exporting Chemicals to Turkey

Many international manufacturers exporting chemical substances to Turkey require local regulatory support for KKDIK compliance.

Kavi Consultancy supports:

• international manufacturers,
• Turkish importers,
• distributors,
• and Only Representative (OR) structures

throughout different stages of KKDIK registration and compliance procedures.

Technical CAS-Based Evaluation Approach

One of the most common mistakes in KKDIK processes is evaluating products only by their commercial names.

However, KKDIK obligations are assessed based on:

• CAS numbers,
• annual tonnage,
• substance composition,
• and import structure.

Kavi Consultancy supports companies with technical CAS-based evaluations in order to reduce process risks and avoid incorrect registrations.

Support for KKDIK Individual Interim Registration

Following the Ministry announcement dated 06 March 2026, many companies started reviewing their options regarding KKDIK Individual Interim Registration.

Kavi Consultancy provides support regarding:

• pre-SIEF / pre-MBDF checks,
• interim registration evaluations,
• tonnage assessments,
• KKS system procedures,
• and registration status reviews.

Practical and Fast Communication

KKDIK procedures may become highly technical and time-sensitive.

For this reason, companies often require:

• fast communication,
• practical guidance,
• and direct technical support.

Kavi Consultancy aims to provide clear and practical communication throughout the entire process.

Process Planning Before Critical Deadlines

Many companies wait until the final period before starting KKDIK procedures. However, registration planning may take longer than expected, especially when multiple substances and different tonnage bands are involved.

In many cases, companies first need to:

• review existing substance inventories,
• identify active CAS numbers,
• calculate annual tonnage ranges,
• review previous registrations,
• and verify current regulatory status.

These evaluations may require additional technical review before the actual registration stage begins.

Guidance for Companies New to KKDIK

Many companies exporting chemicals to Turkey are still unfamiliar with Turkish chemical legislation and may not fully understand how KKDIK requirements apply to their products.

Kavi Consultancy supports companies by helping them understand:

• whether their substances fall within the KKDIK scope,
• which registration obligations may apply,
• how tonnage calculations are performed,
• and which technical steps should be evaluated before starting the process.

This approach helps companies better understand their current position before proceeding with technical registration activities.

Regulatory Review of Existing Substance Portfolios

Many companies currently exporting chemicals to Turkey do not have a complete overview of how their substance portfolio is evaluated under KKDIK.

In practice, companies often discover that:

• the same CAS number exists in multiple products,
• annual tonnage calculations were underestimated,
• certain substances were imported through different distributors,
• or previous registration activities were initiated under different company structures.

For this reason, one of the most important stages before starting KKDIK processes is conducting a detailed portfolio review.

This type of technical evaluation may help companies identify possible compliance risks at an earlier stage and improve overall process planning.

Importance of Correct Substance Identification

One of the most critical technical issues in KKDIK processes is correct substance identification.

Many products are marketed under commercial product names, while KKDIK evaluations are performed based on the actual chemical substance and CAS number.

In some cases:

• similar trade names may contain completely different substances,
• the same substance may appear under different commercial names,
• or imported mixtures may contain substances requiring separate evaluation.

For this reason, technical substance identification should always be performed carefully before starting tonnage calculations or registration activities.

Incorrect CAS evaluations may create significant technical problems later in the process.

Managing Multi-Substance Registration Structures

Some companies manage only one or two substances, while others may import or distribute dozens of different chemical substances simultaneously.

In multi-substance structures, the complexity of the process may increase significantly due to:

• different tonnage bands,
• different suppliers,
• changing import volumes,
• multiple product categories,
• and different registration histories.

For this reason, registration planning should be organized systematically rather than handling each substance separately without coordination.

A structured approach may help companies better manage technical documentation, tonnage tracking, and future regulatory obligations.

KKDIK Individual Interim Registration

Evaluation of Existing OR Structures

Many international manufacturers currently operate in Turkey through distributors, importers, or existing Only Representative (OR) structures.

However, over time, companies may experience changes related to:

• distributor networks,
• importer structures,
• representation agreements,
• or regulatory management preferences.

In such situations, it becomes important to evaluate:

• who currently manages the registration process,
• whether previous registrations remain active,
• how existing pre-SIEF records appear in the system,
• and whether additional technical actions may be required.

Without a clear understanding of the existing structure, companies may face complications during future registration activities.

Technical Review Before Ministry Submission

Submitting information to the KKS system is only one part of the process.

Before any submission, companies should first review:

• substance identities,
• tonnage ranges,
• importer details,
• use information,
• existing registration records,
• and technical data availability.

Many technical problems arise not because of the system itself, but because incorrect or incomplete information is entered at the beginning of the process.

For this reason, preliminary technical review is often one of the most important stages of KKDIK compliance management.

KKDIK Individual Interim Registration

Importance of Early Preparation

One of the most common mistakes companies make is assuming that KKDIK procedures can be completed quickly at the last moment.

In reality, registration preparation may require time for:

• internal data collection,
• supplier communication,
• tonnage calculations,
• document review,
• technical evaluation,
• and regulatory planning.

This becomes even more important for companies managing multiple suppliers or large product portfolios.

Early preparation may help reduce both technical risks and operational delays during the registration process.

Supporting Long-Term Compliance Planning

KKDIK compliance should not be viewed only as a one-time registration activity.

Chemical regulations may require continuous monitoring of:

• annual tonnage changes,
• supplier updates,
• formulation modifications,
• distributor structures,
• and future regulatory developments.

For this reason, companies often benefit from establishing a long-term regulatory management strategy instead of focusing only on a single registration stage.

A structured compliance approach may help companies better manage future operational and regulatory risks within the Turkish market.

KKDIK Individual Interim Registration

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