7 Critical Mistakes Companies Make in the KKDIK Compliance Process and How to Avoid Them

Chemical management and regulatory compliance in Türkiye are no longer limited to occupational safety and environmental protection. Today, KKDIK (Turkey REACH) directly affects business continuity, supply chain reliability, and corporate legal responsibility.

The KKDIK compliance process is not merely a document submission requirement. It requires a multidisciplinary technical approach covering chemical inventories, supplier verification, SDS/GBF documentation, exposure scenarios, and technical dossier preparation.

Field experience consistently shows that many companies still manage KKDIK fragmentedly, reactively, and with incomplete technical control, which significantly increases both regulatory and commercial risks.

This article outlines the 7 most critical technical mistakes observed in KKDIK compliance practices and explains how these risks should be managed correctly.

1. Incomplete or Outdated Chemical Inventory

In many facilities, chemical inventories are kept in fragmented files, without version control and without alignment to current SDS data.
Under KKDIK, inventories must be:

• CAS-based

• Aligned with current SDS

• Supported with annual tonnage information

• Clearly defined by legal role

Incomplete inventories directly result in incomplete registrations.

2. Incorrect Role and Tonnage Determination

Common mistakes include:

• Confusing importer, manufacturer, and downstream user roles

• Misdeclaration when working with an Only Representative (OR)

• Using order-based tonnage instead of annual tonnage

Incorrect role and tonnage data can invalidate the entire registration.

3. Accepting Supplier Declarations Without Verification

Supplier documents are often:

• Outdated

• Technically inconsistent

• Tonnage mismatched

• Unsupported by valid data-sharing agreements

Supplier declarations must always be technically verified.

4. SDS / GBF Documents Not Aligned with KKDIK

Many companies still use:

• Old MSDS formats

• SDS prepared under EU CLP without KKDIK adaptation

• Documents not revised under Turkish regulatory requirements

SDS are the scientific backbone of the registration dossier.

5. Postponing IUCLID Dossier Preparation

IUCLID dossiers include:

• Substance identification

• Physicochemical data

• Toxicological and ecotoxicological data

• Use descriptions

• Exposure scenarios

These dossiers require long-term technical preparation and should never be left to the last minute.

6. Missing Exposure Scenarios and Safe Use Conditions

KKDIK registration also requires:

• Operational conditions

• Worker exposure assessment

• Environmental release evaluation

• Risk management measures

Missing exposure data represents one of the most critical audit nonconformities.

7. Managing the Process Reactively Instead of Strategically

KKDIK is often treated as a last-minute documentation task. In reality, the process involves:

• Consortium participation

• Data-sharing agreements

• Laboratory testing strategies

• Cost-sharing models

Reactive management results in uncontrolled financial and regulatory risks.

Conclusion: KKDIK Is Not Paperwork — It Is Corporate Risk Management

KKDIK compliance plays a direct role in supply chain security, business continuity, and corporate reputation. When treated as a documentation exercise only, it exposes companies to uncontrolled long-term risks.

At Expert PSR, we provide technical and strategic consultancy in:

• Chemical inventory creation and validation

• Role and tonnage analysis

• Supplier compliance verification

• SDS / GBF technical revision

• IUCLID technical dossier preparation

• KKDIK registration and compliance strategy development

If you aim to manage your KKDIK obligations in a safe, transparent, and sustainable manner, you may contact us for structured technical support.