About the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (KKDIK)

The Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (TURKREACH/KKDIK), implemented by the Ministry of Environment, Urbanisation and Climate Change within the framework of harmonisation with the EU REACH Regulation, was published in the Official Gazette on 23 June 2017 (No. 30105, Repeated). The regulation, long awaited by the industry, entered into force on 23 December 2017, six months after its publication, with the exception of provisions granted a transition period under Article 66.

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Through this regulation, the obligations introduced by the REACH Regulation in the European market—such as registration, evaluation, authorisation, notification, and restriction—are now also applicable to substances placed on the Turkish market.

The main objective of KKDIK is to ensure a high level of protection for human health and the environment, to encourage alternative methods for assessing the hazards of substances, and to promote competitiveness and innovation. It sets out the administrative and technical requirements for the registration, evaluation, authorisation, and restriction of chemicals. Manufacturers, importers, and downstream users (meaning natural or legal persons established in Türkiye, other than a manufacturer or importer, who use a substance on its own or in a mixture during their industrial or professional activities, excluding distributors or consumers) are responsible for ensuring that substances are produced, placed on the market, or used without adversely affecting human health or the environment. The Ministry is responsible for overseeing the processes of registration, evaluation, authorisation, and restriction of chemical substances under the KKDIK Regulation.

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Substances on their own, in mixtures, or in articles may not be manufactured or placed on the market unless they are registered in accordance with the relevant provisions. A manufacturer or importer producing or importing one tonne or more of a substance per year is obliged to submit a registration dossier to the Ministry. Article producers or importers must also register a substance if the total amount of the substance in the articles exceeds one tonne per year per producer/importer and if the substance is intended to be released under normal or reasonably foreseeable conditions of use.

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A natural or legal person established outside Türkiye who manufactures a substance, prepares a mixture, or produces an article intended for import into Türkiye may, by mutual agreement, appoint a natural or legal person established in Türkiye as an “only representative” to fulfil the obligations of importers under this Regulation. In this case, the only representative is considered the importer. The only representative must have sufficient knowledge regarding the substance and its uses. If an only representative is appointed, the non-Turkish manufacturer must inform the importers in the same supply chain. These importers are then considered downstream users under the scope of the Regulation.