KKDIK Individual Temporary Registration (ITR) Deadline – 30 September 2026

The Turkish Ministry of Environment, Urbanization and Climate Change introduced significant updates to the KKDIK registration process through its announcement published on 6 March 2026. These changes are intended to accelerate the establishment of the Türkiye Chemicals Inventory and ensure that all substances placed on the Turkish market are properly identified within the national registration system.

As part of this transition, companies manufacturing or importing chemical substances into Türkiye should promptly review their regulatory obligations and determine the most appropriate registration strategy. The Ministry has announced that Individual Temporary Registration (ITR) may be used, where applicable, as part of this process, with a submission deadline of 30 September 2026, regardless of the applicable tonnage band.

Recent Developments in the Türkiye Chemicals Inventory

Türkiye is progressing towards the establishment of a comprehensive national chemicals inventory as part of the implementation of the KKDIK Regulation (Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals). To support this objective, the Ministry of Environment, Urbanization and Climate Change has introduced a series of regulatory measures designed to facilitate the registration of chemical substances and improve the efficiency of the overall registration process.

The creation of the Türkiye Chemicals Inventory is intended to provide a complete record of substances manufactured in or imported into the Turkish market. By improving the identification and traceability of chemicals throughout the supply chain, the inventory will strengthen regulatory oversight while contributing to the protection of human health and the environment.

Under the current transitional framework, companies subject to KKDIK registration requirements are expected to obtain the appropriate registration status—including Full Registration or Temporary Registration—by 30 September 2026 in accordance with the Ministry's latest announcements.

This guide outlines the key regulatory updates and explains:

• The objectives of the Türkiye Chemicals Inventory

• Recent changes to the KKDIK registration framework

• The Individual Temporary Registration (ITR) process

• New opportunities available within MBDF structures

• Practical steps for developing an effective registration strategy

Why the Türkiye Chemicals Inventory Matters

The establishment of the Türkiye Chemicals Inventory represents a significant milestone in the implementation of the KKDIK Regulation. By creating a comprehensive database of chemical substances manufactured in or imported into Türkiye, the Ministry aims to enhance regulatory oversight and establish a more transparent and efficient chemicals management system.

The inventory is designed to support several key regulatory objectives, including:

• Identifying all chemical substances placed on the Turkish market

• Improving the traceability of substances throughout the supply chain

• Strengthening chemical safety and risk management practices

• Supporting the protection of human health and the environment

• Further aligning Türkiye's chemicals legislation with the principles of the EU REACH Regulation

To achieve these objectives, the Ministry has introduced transitional registration measures requiring companies to register eligible substances within the national chemicals registration system. These measures are intended to ensure that all substances subject to the KKDIK Regulation are accurately recorded and managed under a unified regulatory framework.

Transitional Phase of the KKDIK Registration System

To facilitate the transition to the full implementation of the KKDIK Regulation, the Ministry has introduced a temporary registration framework. This transitional period is intended to provide companies with sufficient time to complete their registration obligations while supporting the development of the Türkiye Chemicals Inventory.

By 30 September 2026, every substance subject to KKDIK registration must be covered by an appropriate registration status. Depending on the circumstances of the substance and its registration strategy, companies may obtain one of the following:

• Full Registration Number

• Temporary Lead Registration Number

• Temporary Member Registration Number

• Individual Temporary Registration (ITR) Number

The 30 September 2026 deadline applies irrespective of the annual tonnage band. Companies should ensure that each substance subject to registration is assigned the appropriate registration number before the deadline to maintain compliance with the KKDIK Regulation.

The completion of these registration processes will enable the Ministry to establish a comprehensive and reliable national inventory of chemical substances placed on the Turkish market, providing greater regulatory transparency and supporting the effective implementation of chemical safety legislation.

Updated Procedures and Principles for Temporary Registration

The Procedures and Principles (P&P) published on 5 August 2025 established the operational rules governing temporary registration under the KKDIK Regulation. These provisions introduced separate timelines for temporary registrations submitted by Lead Registrants and Member Registrants within MBDF structures.

Following the Ministry's latest regulatory announcement, these previously independent deadlines have been consolidated into a single compliance date to simplify the registration process and improve regulatory consistency.

Accordingly, both Temporary Lead Registration and Temporary Member Registration must now be completed by 30 September 2026.

This revision provides companies with greater flexibility in planning their registration activities, aligns all temporary registration procedures under a common deadline, and supports a more efficient implementation of the KKDIK registration framework across the Turkish chemicals industry.

Individual Temporary Registration (ITR)

One of the most significant regulatory changes introduced under the updated KKDIK framework is the availability of Individual Temporary Registration (ITR). This mechanism enables companies to fulfil their temporary registration obligations independently where participation in a joint registration is not feasible before the regulatory deadline.

An ITR may be submitted even if the activities within the relevant Substance Information Exchange Forum (MBDF)have not yet progressed to a joint registration submission.

Companies may choose this registration route where there are justified technical, legal or commercial reasons, including:

• Disagreements regarding data sharing or cost allocation

• Confidentiality concerns associated with proprietary information

• Unresolved discussions on data ownership or data selection

• Technical or commercial obstacles preventing participation in the joint submission

In such cases, the registrant must submit an appropriate justification through the Chemical Registration System (KKS)as part of the Individual Temporary Registration application.

MBDF Scenarios Eligible for Individual Temporary Registration

The Individual Temporary Registration mechanism is designed to provide flexibility across different MBDF structures. Depending on the status of the substance within the MBDF, companies may still be eligible to submit an ITR.

Typical scenarios include:

• A Lead Registrant has already submitted a Full Registration dossier, but a member company has justified reasons for registering independently.

• A Lead Registrant has been appointed, although the joint registration dossier has not yet been submitted.

• No Lead Registrant has yet been appointed within the MBDF.

This approach allows companies to continue meeting their regulatory obligations without being entirely dependent on the progress of the joint registration process.

Changes to Temporary Lead Registration

The Ministry has also revised the Temporary Lead Registration timetable.

Under the updated regulatory framework, the previous deadline has been replaced by a single harmonised deadline of 30 September 2026 for both Temporary Lead Registrations and Temporary Member Registrations.

This amendment provides greater certainty for Lead Registrants and MBDF participants while allowing registration activities to be coordinated more efficiently.

Submission of Temporary Registrations with Incomplete Information

Recognising that certain technical information may not always be available before the submission deadline, the Ministry has introduced additional flexibility for registrants.

Where information required under the Procedures and Principles cannot be generated within the applicable timeframe, companies may proceed with a Temporary Registration by submitting a documented justification through the Chemical Registration System (KKS).

Any outstanding information may subsequently be completed in accordance with the regulatory timelines established for the transition to Full Registration.

Companies Already Holding a Full Registration Number

Companies that have already obtained a valid Full Registration Number for a substance are not required to submit a Temporary Registration or an Individual Temporary Registration for the same substance.

Additional Time for Full Registration

Where the studies or technical data required for Full Registration cannot reasonably be completed within the standard deadlines, the Ministry may allow an additional period of up to two years for completion.

During this period, progress relating to data generation and dossier completion will be monitored through the Ministry's Chemicals Consultation Group.

Recommended Compliance Strategy

Companies are encouraged to establish their registration strategy as early as possible by following these steps:

1. Identify all substances manufactured in or imported into Türkiye.

2. Verify whether an Only Representative (OR) has been appointed by the non-Turkish manufacturer and confirm supplier coverage.

3. Review the substance status within the relevant MBDF.

4. Assess the progress of the Lead Registrant and the joint registration process.

5. Determine whether an Individual Temporary Registration is required.

6. Continue preparations for Full Registration and participation in the MBDF where applicable.

Frequently Asked Questions

Which substances are subject to KKDIK registration?

Chemical substances manufactured or imported into Türkiye in quantities of 1 tonne or more per year are generally subject to registration under the KKDIK Regulation.

Is Individual Temporary Registration mandatory?

No. Individual Temporary Registration is an optional compliance mechanism. It is primarily intended for companies that are unable to participate in a joint registration before the applicable deadline.

What happens if no registration is completed by 30 September 2026?

Following the deadline, the Ministry may verify whether substances placed on the Turkish market hold a valid registration number. Pre-MBDF numbers are not considered valid registration numbers. Substances that do not hold a Full Registration, Temporary Registration or Individual Temporary Registration number may be considered non-compliant with the KKDIK Regulation.

Does Individual Temporary Registration replace Full Registration?

No. Individual Temporary Registration is a transitional measure only. Companies remain responsible for completing the Full Registration process within the applicable regulatory deadlines.

Is Temporary Registration required if a Full Registration Number has already been obtained?

No. Once a substance has received a valid Full Registration Number, no additional Temporary Registration is required for that substance.

Conclusion

The latest regulatory developments under the KKDIK Regulation provide companies with greater flexibility while supporting the establishment of the Türkiye Chemicals Inventory.

Businesses should review their registration obligations well before 30 September 2026 and determine the most appropriate registration pathway, whether through Full Registration, Temporary Registration or Individual Temporary Registration (ITR).

Early planning not only reduces regulatory risk but also facilitates more effective participation in MBDF activities and ensures a smoother transition to Full Registration.

If you require assistance with your KKDIK registration strategy, MBDF assessment or Individual Temporary Registration, our regulatory specialists are available to support you throughout every stage of the process.