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2025 KKDIK Updates – What You Need to Know

Introduction

The Turkish KKDIK Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals – “Turkey REACH”) continues to evolve. In 2025, several important updates and transitional provisions are shaping how companies should prepare for compliance in Turkey. These changes directly affect manufacturers, importers, and Only Representatives (ORs).

Key Deadlines

  • Pre-MBDF (pre-SIEF / pre-registration) Notifications
    All existing substances placed on the Turkish market must be notified in the Pre-MBDF system by 31 October 2025.

    • New substances must be notified within 30 days of being placed on the market.

    • Pre-MBDF reference numbers will be required for participation in SIEF/Consortium discussions.

  • Registration Deadlines (unchanged but reaffirmed in 2025 updates):

    • 31 December 2026 – ≥1,000 t/y, CMR Cat. 1A/1B ≥1 t/y, or high aquatic hazard substances.

    • 31 December 2028 – ≥100 t/y.

    • 31 December 2030 – ≥1 t/y.

 

Practical Impact

  • For non-Turkish manufacturers: It is essential to appoint a qualified Only Representative in Turkey to safeguard your market access.

  • For importers: Proper DU (Downstream User) agreements and OR notifications are required to ensure exemption from direct registration duties.

  • For all actors: Early organization will reduce compliance costs and prevent last-minute regulatory risks.

 

How We Support You

As your compliance partner, we provide:

  • Pre-MBDF submission and reference number management.

  • SIEF/Consortium representation and negotiation support.

  • Full KKDIK dossier preparation via KKS system.

  • Authoring of SDS compliant with Turkish SEA (CLP) and KKDIK Annex II.

  • Strategic advice on timelines, LoA negotiations, and budget planning.

Lisam Systems Turkey

+90 (232) 282 10 35

+90 (262) 32 000 32

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