KKDIK: Roadmap After October 31 — 2026 Provisional Registration Timeline (Lead & Member)

As of October 31, 2025, the critical threshold of the Pre-MBDF / pre-MBDF phase is behind us. From now on, waiting with the mindset that "the dossier can be prepared one day" results in market supply disruption + cost + coordination crisis for most companies.

This article clarifies who should do what, and by when, and also shares a practical plan to manage the process quickly and with low risk with Pier Compliance.

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60-second summary (TL;DR)

• If lead selection is delayed, the entire joint registration group slows down.
• If the full registration dossier won't be ready, provisional registration by March 31, 2026 for the lead; member registration entries via KKS by September 30, 2026 for members are critical.
• Fastest progress: (1) substance/tonnage mapping → (2) MBDF communication → (3) lead + contract → (4) provisional registration plan.

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Critical dates and "who, what to do?" table

Date	Who?	What needs to be done?	Output
October 31, 2025	All potential registrants	Completion of Pre-MBDF (pre-MBDF) submissions	Groundwork for MBDF communication
December 31, 2025	Joint registration group	Determine lead company for substances currently on the market	Lead + role distribution
March 31, 2026	Lead registrant (and/or individual registrant)	Provisional Registration if full registration dossier won't be ready	Bridge for market continuity
September 30, 2026	Member registrants	Complete member registration entries after lead provisional registration	Group alignment
December 31, 2026	High tonnage / high hazard groups	1st threshold full registration obligations (tonnage/hazard-based)	Full registration
December 31, 2028	Medium tonnage	2nd threshold full registration	Full registration
December 31, 2030	All substances ≥ 1 ton/year	3rd threshold full registration	Full registration

Note: 2026/2028/2030 full registration thresholds vary based on portfolio/tonnage/hazard classification. Therefore, the plan should be a portfolio-based timeline, not a "single timeline".

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New game after October 31: the "process" is now in KKS

The Ministry has activated the registration module in KKS. In practice, the process progresses in the following order:

1. Completion of Pre-MBDF submissions
2. MBDF communication and lead selection for each substance
3. Joint registration contract between lead + potential registrants (data sharing, cost sharing, management rules)
4. Creation and submission of provisional registration / registration dossiers

This flow doesn't eliminate the internal "we'll handle it later" approach; on the contrary, it requires more documentation and coordination.

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What is your role? (Lead, Member, Individual) — choosing the right route

1) Lead registrant (Leader)

The most critical risk is with the lead: because the lead sets the group's pace.

7 areas the lead "must" manage:

• Establishment of substance management and registration flow in KKS
• Storage of MBDF communication records (audit-ready)
• Member list + communication matrix (who, which country/company, which role)
• Data needs: Annex-1 minimum data set + next phase plan
• Member contract (cost, data, representation, decision-making majority)
• Provisional registration application (if full dossier won't be ready)
• Test/data strategy for "Full registration" (gap assessment + data acquisition)

2) Member registrant (Member)

The most common mistake on the member side: saying "the lead will handle it" and being caught unprepared.

6 steps members must take immediately:

• Clarify substances in your portfolio by CAS/EC basis
• Calculate tonnage band with last 3 years average
• Roughly classify your uses (SU/PROC/PC/AC) if necessary
• Clarify your role in MBDF (are you a data holder, or just a member?)
• Request/review the lead contract draft early
• Assign an internal responsible person for KKS member registration entries

3) Individual registration (Separating from Joint)

Individual registration is not always "easy". In most cases:

• Data costs increase,
• Defensible justification is required,
• The process requires more internal resources.

Therefore, the individual registration decision should be made portfolio-based (substance criticality/supply risk/tonnage/hazard).

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Steps to take today: 14-day "quick start" plan

The plan below works with "least friction" for both leads and members.

Days 1–3: Portfolio & tonnage mapping

• Substance inventory (CAS/EC/name, mixture content, article content)
• Tonnage calculation (last 3 years average + 2026 projection)
• Hazard classes (via SEA/CLP classification)
• "Critical substance list" (first 10–30 substances that would cause market disruption)

Output: "Substance-Tonnage-Hazard-Criticality" Excel table.

Days 4–7: MBDF communication + lead selection groundwork

• Initiate/verify MBDF communication for each substance
• List of potential registrants and communication channel
• Criteria for lead candidates: data access, coordination capacity, time
• Decision-making method: simple majority, representation, meeting minutes

Output: "Candidate + justification + vote/decision record" for lead selection.

Days 8–10: Contract draft (the most delayed part)

If the joint registration contract is written at the last minute, the process gets stuck. A good contract should have at minimum these headings:

• Data sharing and data ownership
• Cost sharing (tonnage/role-based)
• Membership conditions, withdrawal conditions
• Decision-making mechanism and disputes
• Timeline and deliverables (provisional registration / member entries / full registration)
• Confidentiality and competition rules

Output: Contract ready for signature + task distribution.

Days 11–14: Provisional registration plan (application if needed)

• Will the full registration dossier be ready? (gap assessment)
• If not: prepare data set for lead provisional registration
• KKS member entry plan for member companies (timeline + responsible persons)
• Internal approval: alignment with management, supply chain, sales plan

Output: "Provisional Registration / Member Entries" master plan.

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For those who haven't pre-registered: recovery is still possible (but costs increase)

If you've fallen behind in the Pre-MBDF / pre-registration process:

• The process is not "finished"; however, delay pushes you to a more expensive and riskier route.
• Correct approach:
  1. Clarify OR/representation model
  2. Perform substance/tonnage mapping
  3. Prioritize critical substances
  4. Proceed with correct flow on KKS

Biggest mistake: Rushing and submitting "wrong files". Incorrect classification/incorrect tonnage/incorrect role; correcting them later is more expensive.

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Risk matrix: What do you lose?

Risk	If you plan early	If left to last minute
Market supply continuity	Manageable	Risk of disruption increases
Cost	Controlled budget	Panic spending + urgent data costs
Data access	Planned	Data holders full → delay
Internal organization	Clear roles	"Who will do it?" crisis
Audit/traceability	Audit-ready	Scattered correspondence, weak evidence

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The "fastest and lowest risk" path with Pier Compliance

We manage this process end-to-end as: portfolio-based timeline, KKS operations, MBDF coordination, lead/member contract set, provisional registration data set, and subsequently full registration roadmap.

5 deliverables you can request from us for quick start

1. Substance-tonnage-criticality inventory (Excel)
2. MBDF communication plan + lead selection document
3. Joint registration contract (TR/EN) + role matrix
4. Provisional registration data set preparation + KKS process support
5. Full registration "gap assessment" + budget/timeline

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FAQ (Frequently Asked Questions)

When is provisional registration necessary?

If the full registration dossier won't be ready by the relevant deadline, the provisional registration mechanism comes into play to maintain market supply continuity.

Who should be the lead?

A company with strong data access, capable of managing coordination, and able to carry the timeline. The lead's "technical knowledge + project management" capacity is critical.

When should members make entries to KKS?

After the lead provisional registration flow is completed, members should complete their member entries in a planned manner.

If I missed Pre-MBDF, is the process finished?

Generally, the process can be recovered; however, delay increases cost and supply risk. Portfolio-based prioritization is essential.

Why is the SDS (GBF) side critical in this process?

In KKDIK compliance, correct classification + correct use information + correct tonnage form the foundation of the registration strategy. If SDS quality is low, the registration strategy is also weak.

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Contact (For quick roadmap)

Reach out to us with substance list + tonnage band + supply model (import/manufacture); let's create the fastest and lowest-risk plan within the same day.

info@piercompliance.com
www.piercompliance.com