The Procedures and Principles on the Implementation of the KKDIK Regulation (MoEUCC Sayı 21408564-020-13216050), issued by the Ministry of Environment, Urbanisation and Climate Change and in force since August 5, 2025, requires every Madde Bilgisi Değişim Forumu (MBDF) participant to submit member registration dossiers through the Kimyasal Kayıt Sistemi (KKS) portal by September 30, 2026.
Turkish manufacturers and importers of substances at or above 1 tonne per year, non-Turkish makers placing on the Turkish market via a Sorumlu Temsilci (Only Representative), and lead and member registrants in KKDIK joint submissions must submit member registration dossiers via the KKS portal under a signed joint-registration Sözleşme (data and cost-sharing contract) with the lead registrant by September 30, 2026, or those substances cannot be manufactured in or placed on the Turkish market.
- Deadline : September 30, 2026 (member dossier submission)
- Who : Turkish manufacturers and importers of substances at or above 1 tonne per year, non-Turkish makers via a Sorumlu Temsilci, and lead and member registrants of KKDIK joint submissions
- What : Submit member registration dossiers via the KKS portal under a signed joint-registration Sözleşme with the lead registrant
- Otherwise : Substances manufactured in or imported into Turkey at or above 1 tonne per year must be registered; those not registered via the joint submission cannot be manufactured in or placed on the Turkish market
- Official source : KKDİK Usul ve Esaslar, Sayı 21408564-020-13216050 (PDF)
What is due on September 30, 2026
The obligation due on September 30, 2026 is the member dossier submission, the final step of the KKDIK joint-registration sequence the Usul ve Esaslar operationalises under Environment Law No 2872 and the KKDIK Yönetmeliği (RG 30105 Mükerrer). It entered into force on August 5, 2025 and sequences the parent regulation's tonnage-based deadlines into a pre-registration, lead dossier, then member dossier ladder through the KKS portal.
| Step | Date |
|---|---|
| Pre-MBDF (pre-registration) submission | October 31, 2025 |
| Lead registrant (lider kayıt ettiren) selection | December 31, 2025 |
| Lead dossier and provisional registration (geçici kayıt) deadline | March 31, 2026 |
| Member dossier submission | September 30, 2026 |
Who is covered
The instrument applies the tek madde tek kayıt (one substance, one registration) principle to every substance manufactured in or imported into Turkey at or above 1 tonne per year. Turkish manufacturers and importers of substances who submitted an ön-MBDF (pre-MBDF) by October 31, 2025 are MBDF participants and must file member dossiers.
Non-Turkish substance manufacturers placing on the Turkish market must act through a Sorumlu Temsilci (Only Representative), mandatory under KKDIK. Lead registrants (lider kayıt ettiren) who submitted the lead dossier by March 31, 2026 complete the joint submission; members file under that lead. A provisional registration (geçici kayıt), available where the lead registrant could not complete the full Annex 1 dossier by March 31, 2026, does not remove the member dossier duty.
What to do before September 30, 2026
- Sign the joint-registration Sözleşme (data and cost-sharing contract) with the lead registrant.
- Submit the member registration dossier via the KKS portal under that signed Sözleşme.
- Confirm the lead dossier was submitted by March 31, 2026, or that a provisional registration (geçici kayıt) covers the substance.
- Verify your ön-MBDF (pre-MBDF) was filed by October 31, 2025.
- Appoint a Sorumlu Temsilci (Only Representative) if you are a non-Turkish manufacturer placing on the Turkish market.
What happens otherwise
Substances manufactured in or imported into Turkey at or above 1 tonne per year must be registered; those not registered through the joint submission cannot be manufactured in or placed on the Turkish market after September 30, 2026. MoEUCC administers the regime through its General Directorate of Environmental Management (ÇYGM), which operates the KKS portal; TOBB provides the joint-registration framework. Obsidian's per-jurisdiction monitoring surfaces deadlines of this kind at publication.
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