KKDIK Before 30 September 2026: Critical Checks on Only Representative, LoA, Individual Provisional Registration and Pre-SIEF

As the 30 September 2026 deadline approaches, companies should no longer ask only whether they have "done something" under KKDIK.

The more important question is:

Can the company demonstrate the actual registration status of every substance it manufactures or imports, and can it prove that the relevant supply chain is properly covered?

For importers in particular, four areas require closer attention:

• the validity of the Only Representative (OR) structure,

• whether the Turkish importer is actually covered by that OR,

• whether individual provisional registration should be considered when the Lead Registrant or Letter of Access process remains unresolved, and

• whether a Pre-SIEF notification is being incorrectly treated as an actual registration.

These issues all lead to the same fundamental compliance question:

Will your company be able to demonstrate the KKDIK registration status of each substance after 30 September 2026?

This article examines these issues in the context of the KKDIK Regulation and the Ministry's current implementation framework.

1. The basic principle: No registration, no market

The fundamental registration principle under KKDIK is established in Article 6 of the Regulation.

A substance subject to registration requirements cannot be manufactured or placed on the market unless it has been registered in accordance with the Regulation.

Article 7 further establishes the general registration obligation for manufacturers and importers of substances in quantities of one tonne or more per year, whether the substance is supplied on its own or in a mixture.

A practical KKDIK assessment should therefore follow a structured sequence:

What is the substance? → What is the annual tonnage? → What is the company's role in the supply chain? → Does an exemption apply? → Who is responsible for registration? → How is that registration obligation being fulfilled?

Any uncertainty within this chain should be treated as a compliance risk, particularly as the 30 September 2026 deadline approaches.

2. Why "our foreign supplier has an OR" may not be sufficient

One of the most common statements made by Turkish importers is:

"Our supplier has an Only Representative in Türkiye, so we are covered under KKDIK."

That may be correct.

However, the mere existence of an OR is not sufficient to confirm compliance.

Who may appoint an Only Representative?

Article 9 of KKDIK provides the legal basis for the Only Representative mechanism.

Under Article 9(1), a natural or legal person established outside Türkiye who:

• manufactures a substance,

• formulates a mixture, or

• produces an article

may appoint a natural or legal person established in Türkiye as its Only Representative to fulfil the relevant obligations of importers under KKDIK.

There is an important distinction here.

A company acting solely as a trader or distributor is not listed among the entities entitled to appoint an OR under Article 9(1).

Therefore, it would not be appropriate to assume that a foreign company acting exclusively as a trader or distributor may appoint an OR merely in that capacity.

However, this should not be oversimplified.

A company commercially described as a "trader" may also be the actual manufacturer, formulator or article producer for a particular product.

The correct question is therefore not simply:

"Is this company a trader?"

The correct question is:

"What is the legal and supply-chain role of the non-Turkish entity that appointed the OR under Article 9 of KKDIK?"

3. Why generic "KKDIK compliant" declarations may not be sufficient

Importers frequently receive supplier declarations containing statements such as:

"KKDIK compliant"

"OR appointed"

"Covered by our Only Representative"

"Registration process ongoing"

These statements may be useful.

However, they do not automatically demonstrate that the Turkish importer is fully covered.

Under KKDIK, the key issue is not only whether an OR exists but whether the relevant supply chain has been correctly linked to that OR structure.

Under Article 9(2), the Only Representative is required to maintain up-to-date information concerning the quantities imported and the customers supplied.

Article 9(3) also requires the non-Turkish entity appointing the OR to inform importers within the same supply chain of the appointment.

A proper compliance verification chain should therefore look like this:

Foreign manufacturer/formulator → Only Representative → Substance → CAS/EC → Turkish importer → Imported quantity

rather than simply:

Foreign supplier → OR exists

This distinction becomes particularly important in complex supply chains involving multiple manufacturers, traders, distributors and Turkish importers.

4. Does the existence of an OR automatically remove the importer's obligations?

A properly appointed Only Representative may fulfil the relevant importer registration obligations on behalf of the non-Turkish manufacturer, formulator or article producer it represents.

However, the specific Turkish importer must actually be included within the relevant OR coverage.

The importer should therefore be able to retain documentary evidence covering, at a minimum:

• the identity of the foreign manufacturer or formulator,

• the identity of the Only Representative,

• the relevant substance or substances,

• the Turkish importer covered by the arrangement, and

• the relevant quantities imported.

Companies that have relied for years on a generic statement such as "our supplier has an OR" should consider re-verifying this structure.

The existence of an OR and the confirmation that a particular Turkish importer is covered for a particular substance and tonnage are not the same compliance question.

5. What is a Letter of Access and why does it matter?

Where several registrants are registering the same substance, KKDIK is based on the principle of one substance – one registration, with certain information being submitted jointly and relevant data being shared among registrants.

In practice, a Letter of Access (LoA) is commonly used to provide a registrant with the right to refer to studies or data controlled by another party for registration purposes.

However, purchasing an LoA does not by itself mean that a KKDIK registration has been completed.

Similarly, the fact that LoA discussions have not yet been finalised does not necessarily mean that the company has no possible action before 30 September.

This is where the individual provisional registration mechanism becomes particularly relevant.

6. Why did individual provisional registration become important?

The current KKDIK implementation framework was further shaped by the Procedures and Principles for the Implementation of the KKDIK Regulation, which entered into force on 5 August 2025.

During the Chemicals Advisory Group meeting held on 3 March 2026, the Ministry indicated that difficulties in establishing Lead Registrant structures were causing delays and that allowing provisional registrations to proceed individually could provide a faster and more effective solution.

According to the Ministry's announcement:

An individual provisional registration dossier may be submitted through KKS provided that the justification for the individual submission is clearly stated.

The Ministry also explicitly identified 30 September 2026 as the relevant deadline for these individual provisional registrations.

This mechanism is particularly important for substances where:

• no effective Lead Registrant structure has been established,

• joint registration activities are not progressing, or

• significant practical delays remain unresolved.

7. Is it correct to say "no LoA is required for individual provisional registration"?

That statement is too broad.

A more accurate approach is:

Where the Lead Registrant, LoA or data-sharing process remains unresolved, the applicability of individual provisional registration should be assessed on a substance-by-substance basis.

Why?

Because individual provisional registration and the right to use regulatory data are not the same issue.

The ability to submit an individual provisional dossier does not give a registrant the right to use third-party studies without the necessary ownership, access or reference rights.

KKDIK's data-sharing and study-reference requirements continue to apply.

The Ministry's data-sharing guidance also makes clear that submitting information separately does not automatically eliminate the registrant's data-sharing obligations.

Individual provisional registration therefore does not mean:

"LoA is no longer required."

Nor does it mean:

"Data-sharing obligations no longer apply."

The provisional registration strategy and the long-term data-access strategy should be treated as two related but separate compliance workstreams.

8. What does Article 12 say about separate submission?

Article 12 of KKDIK establishes the principle that certain information concerning the same substance should be submitted jointly.

However, Article 12(3) also allows certain information to be submitted separately in specified circumstances, including situations where:

• participation in the joint submission would be disproportionately costly,

• joint submission would require disclosure of commercially sensitive information that could cause substantial commercial harm, or

• there is disagreement regarding the selection of information to be submitted.

Such departures must be justified.

A legal distinction should nevertheless be maintained:

Opting out of certain elements of a joint submission under Article 12 and the individual provisional registration mechanism introduced within the Ministry's 2026 implementation framework should not be treated as identical mechanisms.

Article 12 concerns the general legal structure governing joint submission under KKDIK.

Individual provisional registration is an implementation mechanism designed to allow the provisional registration process to progress where the joint process cannot be completed within the current transitional framework.

The common principle is nevertheless clear:

The reason for proceeding separately or individually should be properly documented and justified.

9. Why should Pre-SIEF not be confused with registration?

Another significant compliance risk is the assumption that an old Pre-SIEF notification means that the substance has already been registered.

It does not.

A Pre-SIEF notification primarily serves as an early step enabling potential registrants of the same substance to identify each other and facilitate substance identification, data-sharing and joint-registration activities.

It does not, by itself, constitute the submission of a KKDIK registration dossier.

Therefore:

Pre-SIEF notification ≠ provisional registration

and

Pre-SIEF notification ≠ full registration

This distinction becomes particularly important as 30 September 2026 approaches.

10. What should companies complete before 30 September 2026?

The Ministry's 3 March 2026 announcement explicitly identified 30 September 2026 as the deadline for individual provisional registrations.

Companies should therefore treat September not as the month to start analysing their KKDIK portfolio, but as the period in which outstanding registration gaps should be closed.

This process should not be handled solely by the regulatory department.

Procurement, foreign trade, supply chain, product safety and technical functions may all need to participate.

Preparing a technically valid registration dossier and ensuring that the company's real-world supply chain is correctly covered are related but distinct tasks.

11. KKDIK compliance checklist before 30 September

Companies should review their substance portfolios on a CAS/EC basis using the following approach.

1. Verify substance identity

Confirm the CAS number, EC number, substance name, composition and, where relevant, UVCB identity.

2. Confirm annual tonnage

Determine the manufacturing or import volume and the applicable registration tonnage band.

3. Determine the company's role

Is the company a manufacturer, importer or downstream user?

Is the import covered by an Only Representative?

4. Verify the OR appointment chain

If an OR is used, confirm whether the non-Turkish entity appointing the OR actually qualifies under Article 9 as a manufacturer, formulator or article producer.

5. Confirm Turkish importer coverage

Do not verify only that an OR exists.

Confirm that the relevant Turkish importer, substance and import quantities are actually covered.

6. Review the Lead Registrant and joint-registration status

Has a Lead Registrant been established?

Is the joint-registration process actively progressing?

Is completion realistically achievable?

7. Review the LoA status

Has an LoA been obtained?

Is an offer still pending?

Is there a data-sharing disagreement?

8. Assess the need for individual provisional registration

Where the joint process is not progressing or a Lead Registrant issue remains unresolved, evaluate whether the Ministry's individual provisional registration mechanism is applicable.

Document the justification.

9. Distinguish Pre-SIEF from actual registration

Confirm exactly what type of number or status the company currently holds.

10. Verify KKS records and supporting evidence

The submission status, registration number, OR coverage, supplier information and relevant correspondence should be retained within the company's compliance records.

12. What is the biggest risk for Turkish importers?

The most significant risk is not always the obvious situation where no registration exists.

A more difficult risk to detect is this:

The company believes it is covered, but the registration structure it relies on does not actually cover its imports.

For example:

• a foreign trader may state that "an OR has been appointed";

• the OR may actually represent a different manufacturer;

• the Turkish importer may never have been included within the OR coverage;

• the imported substance identity may not match the registered substance;

• the tonnage may not be properly reflected; or

• the number held by the importer may only be a Pre-SIEF number.

In KKDIK compliance, therefore, the existence of a document is not enough; what that document actually covers matters just as much.

13. When does waiting for an LoA become a commercial risk?

LoA and data-sharing negotiations are a normal part of the KKDIK registration process.

However, as the deadline approaches, the fact that discussions are "ongoing" is not sufficient by itself.

Companies should be able to answer:

"What is our alternative plan if this process is not completed in time?"

Whether that alternative should involve individual provisional registration must be assessed separately for each substance.

Companies should also consider supply continuity.

The risk profile of a critical raw material capable of shutting down production is not the same as that of a low-volume auxiliary chemical that can easily be replaced.

KKDIK portfolios should therefore also be prioritised according to business criticality.

14. Individual provisional registration does not mean the compliance process is finished

Individual provisional registration is an important transitional mechanism.

However, it should not be treated as the final objective.

Submitting an individual provisional registration does not automatically eliminate:

• final registration requirements,

• data-sharing obligations,

• the need to generate required study information,

• rights of access to regulatory data, or

• future obligations relating to the joint registration structure.

Companies should therefore manage two separate workstreams:

the 30 September 2026 compliance plan

and

the long-term KKDIK registration strategy.

The first addresses the immediate transitional registration requirements and market-access risk.

The second ensures that the substance's final registration dossier remains legally and technically sustainable.

Conclusion: The question in September should no longer be "Have we started?" but "Have we closed the gaps?"

KKDIK has been on the Turkish chemical industry's agenda for many years.

As 30 September 2026 approaches, however, repeatedly marking registration files as "in progress" will no longer provide sufficient assurance.

Four issues in particular should now be verified:

Is the Only Representative structure legally valid?

Is the Turkish importer actually covered by the OR?

If the Lead Registrant or LoA process remains unresolved, has an alternative registration strategy been assessed?

Does the company hold only a Pre-SIEF number, or does it actually have provisional or full registration status?

The objective before 30 September should be straightforward:

For every substance within scope, either demonstrate the appropriate registration status or technically and legally document why no registration obligation applies.

True KKDIK compliance is not simply about entering information into KKS.

The substance, tonnage, supplier, foreign manufacturer, Only Representative, Turkish importer and registration status must all be consistent, traceable and demonstrable.

Legal and Official References

Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (KKDIK)
Official Gazette No. 30105, 23 June 2017.
In particular: Articles 6, 7, 9, 11 and 12.

Procedures and Principles for the Implementation of the KKDIK Regulation
Ministry of Environment, Urbanisation and Climate Change – 5 August 2025.

Chemicals Advisory Group Meeting – 3 March 2026
Ministry of Environment, Urbanisation and Climate Change.
Individual provisional registration mechanism and the 30 September 2026 deadline.

KKDIK Data Sharing Guidance
Ministry of Environment, Urbanisation and Climate Change.

Guidance on the Preparation of Registration and PPORD Dossiers
Ministry of Environment, Urbanisation and Climate Change.

Expert PSR

Expert PSR supports companies in evaluating their KKDIK portfolios based on substance identity, CAS/EC number, tonnage, supplier, Only Representative, Turkish importer, Lead Registrant, LoA and registration status, identifying outstanding compliance gaps and establishing an appropriate registration strategy.

The objective before 30 September 2026 is not only to complete registration activities, but also to protect the continuity of the company's supply chain.