2025 KKDIK Procedures and Principles

Procedures and Principles Regarding the Implementation of KKDIK

The “Procedures and Principles Regarding the Implementation of KKDIK” is an official implementation document issued by the Turkish Ministry of Environment, Urbanization and Climate Change. It clarifies how the KKDIK Regulation must be applied in practice.

While KKDIK defines legal obligations, the Procedures and Principles explain the operational mechanism behind:

• Registration system functioning

• Substance Information Exchange Forums (MBDF / SIEF equivalent)

• Lead registrant determination

• Joint registration structure

• Temporary registration process

• Dossier completion and updates

• SDS system obligations

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Key Areas Covered

1. Registration Obligation

Any manufacturer or importer placing a substance on the Turkish market at ≥ 1 ton/year must submit registration information via the Chemical Registration System (KKS).

Pre-MBDF submission is mandatory to participate in substance data sharing and to proceed with registration.​

2. MBDF (Substance Information Exchange Forum)

All potential registrants of the same substance must be part of the same MBDF.
The principles enforce the “one substance – one registration” approach unless a justified opt-out applies.

3. Lead Company Determination

The document defines:

• How lead registrants are selected

• Voting procedures among MBDF members

• Ministry intervention if no volunteer exists

• Leader replacement rules

• Data and document transfer obligations

Leadership is not symbolic — it carries coordination and data responsibilities.

4. Joint Registration Groups

Joint registration groups are responsible for:

• Coordinating dossier preparation

• Organizing data sharing

• Structuring internal agreements

TOBB and sectoral bodies may support model agreement development, but group governance remains with the registrants.

5. Temporary Registration (Critical Transition Mechanism)

If full registration cannot be completed in time, companies may perform temporary registration by submitting defined core data (Annex-1).

Key milestones:

• Lead companies → submit temporary data

• Member companies → follow with their entries

• KDU (Chemical Assessment Expert) involvement required

This is a bridge mechanism, not a replacement for full registration.

6. Completion of Registration

Full registration is considered completed when tonnage-dependent data requirements are met by the relevant deadlines.
Extension requests are possible but must be justified and approved by the Ministry.

Maximum extension period: up to two years beyond the tonnage band deadline.

7. Dossier Updates

Registrants must update dossiers within 3 months when new information triggers update obligations.
Failure to update can lead to regulatory action.

8. Safety Data Sheets (SDS)

The Procedures require:

• SDS upload into the Ministry’s system

• Inclusion of KDU details in Section 16

• Compliance with defined SDS format (Annex-2)

9. Governance Structures

Two advisory bodies are defined:

Chemicals Science Group

• Academic experts

• Technical evaluation role

Chemicals Advisory Group

• Ministries + TOBB + sectoral stakeholders

• Policy and strategic advisory role

10. Enforcement

Non-compliance may trigger sanctions under Environmental Law No. 2872, including administrative penalties and market restrictions.

What This Document Means in Practice

The Procedures and Principles transform KKDIK from a legal text into a working system.
They regulate:

• How companies interact

• How data is shared

• How leadership is assigned

• How delays are managed

• How the Ministry oversees the process

Without understanding this document, companies understand KKDIK theory, but not KKDIK execution.

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