KKDIK Countdown: What Turkey's 30 September Deadline Means for Importers and Manufacturers
September 9, 2026
Turkey's Ministry of Environment, Urbanisation and Climate Change has confirmed that from 30 September 2026, customs authorities will begin strict checks on chemical registration numbers under KKDIK, Turkey's REACH-equivalent regulation. For any company importing substances into Turkey - or manufacturing them domestically - this date marks the point where compliance stops being a paperwork exercise and starts being a condition of market access.
Here's what companies need to know, based on the latest guidance from the Ministry.
Customs controls are coming
From the end of September, customs officers will begin verifying that imported chemical substances carry a valid registration number. Products without one may face sanctions at the border, though the Ministry has not yet clarified exactly what those sanctions will involve.
What is clear is the mechanism: registration numbers are expected to be declared in the customs declaration form, and the Ministry is currently building the technical infrastructure to verify the numbers provided. In practice, this means every consignment subject to KKDIK will need verifiable registration numbers to be declared in the paperwork to ensure successful customs clearance.
Who is responsible?
The obligation sits squarely with whoever is legally responsible for customs clearance - in most cases, the Turkish importer. If a non-Turkish supplier hasn't registered the substance themselves, or hasn't appointed an Only Representative (OR) in Turkey to do so on their behalf, the responsibility doesn't disappear. It transfers to the importer.
That's a critical point for supply chain risk. Importers who assume their suppliers "have it covered" may face issues at customs while the true reason - a missing or invalid registration - has nothing to do with anything they did directly. Confirming registration status upstream, before shipments are en route, is now a practical necessity rather than best practice.
It's not just importers - domestic manufacturers are in scope too
Enforcement isn't limited to the border. The General Directorate of Environmental Impact Assessment, Permit, and Inspection (Çevresel Etki Değerlendirmesi, İzin ve Denetim Genel Müdürlüğü) is responsible for auditing registration compliance across all industrial sectors. Following the 30 September deadline, this authority will begin conducting field and factory audits to verify that domestic manufacturers hold valid registrations for the substances they produce.
In short: whether a substance enters Turkey at the border or is manufactured within it, the Ministry now has an enforcement mechanism prepared and ready to be applied.
Inside the Ministry's KKDIK meeting: three things worth knowing
A recent Ministry meeting on the KKDIK process surfaced several clarifications that should shape how companies prioritise their remaining time before the deadline.
1. Temporary registration is the immediate priority. With limited time left, the Ministry's guidance is to focus on completing temporary registrations for all relevant substances by 30 September, rather than pushing for full registrations now. As of the meeting, roughly 17,000 dossiers (full and provisional combined) had been submitted.
2. Dossier updates shouldn't carry a fee - but sometimes have. The Ministry confirmed that updates to a dossier, other than tonnage band changes and other specifically defined major updates, should not require an additional fee. Similarly, moving from a temporary to a full registration should not trigger an extra fee, though this will need to be reflected in the system at a later stage.
3. Registration numbers are evidence of KKDIK compliance. Once controls begin, a registration number will serve as the primary evidence that a product is compliant. The Ministry noted that dossier access via the registration number is restricted to the Ministry itself and is not shared with third parties. Therefore, sharing these numbers should not present a confidentiality concern.
What this means in practice
With the deadline now weeks away, the practical path for most companies is:
Confirm every KKDIK-scoped substance in your import or production portfolio has, at minimum, a temporary registration in progress or submitted.
Verify supplier and OR status for any non-Turkish-sourced substances - don't assume the obligation is covered upstream.
Prepare for registration numbers to appear in customs paperwork and be ready to produce them on request.
Flag any incorrectly charged dossier-update fees, since the Ministry has confirmed these shouldn't apply outside specifically defined major changes.
The window to act before enforcement begins is short. Companies that treat 30 September as a hard compliance milestone, rather than a soft guideline, will be the ones least exposed when customs checks and factory audits start.
Further reading
