KKDIK Provisional Registration Period: Strategic Preparation in the Data Deficiency Trap

For Turkey's chemical industry, KKDIK (Turkish REACH) is not just a compliance process, but also a data management battle. The Ministry's activation of the provisional registration (pre-registration) system is not a postponement, but rather a strategic "preparation corridor" arising from the fact that many companies in the market do not yet have the technical data required for full registration.

Provisional Registration: A "Calm Before the Storm" Before Full Registration

Provisional registrations are a lifeline for companies that have not yet completed their data sets, finished their testing processes, or managed LoA (Letter of Access) costs. However, this process should not be viewed as a "waiting room."

• Data Deficiency Paradox: While full registration of thousands of chemical substances in the market is planned, a large portion of the inventory experiences technical dossier deficiencies. Provisional registration provides the time needed to fill this gap.

• Market Analysis: Provisional registration data is the most concrete projection showing which substances will be withdrawn from the market and which will be strategically protected.

Lead Registrant Selection: Technical Leadership or Financial Burden?

The Lead Registrant selection, which lies at the heart of the joint registration process, is often perceived as merely an administrative task. However, this is a deep sectoral responsibility.

A Rare Insight: When selecting a lead registrant, it is not sufficient to simply be "the company with the largest tonnage." The lead company is the actor that determines the cost of all MBDF members in tough negotiations (Data Sharing) with REACH data owners. Wrong lead selection can lead to multiplied data costs and rejection of the registration dossier.

Strategic Perspective: Why Are Thousands of Substances Waiting?

There are currently many chemicals planned for registration in the system, but this "quantity" increase brings with it a "quality" risk. It is not enough for companies to simply enter the system; technical dossiers on KKS (Chemical Registration System) must be made compatible with safety data sheets (SDS) that meet EU standards.

• Deep Analysis: When the provisional registration period ends, every substance that remains "unregistered" due to data deficiency means a break in the supply chain. This situation has a domino effect that will shake not only the chemical sector, but all sub-industries from paint to automotive, from textiles to food.

As Pier Compliance, we are not just registering in this transition process, but strengthening companies' technical muscles in data deficiency analysis and Lead Registrant management processes. The future will belong not to those who hold the data, but to those who can manage it.

Source: https://echa.europa.eu/-/echa-takes-on-additional-tasks-to-strengthen-chemical-safety-in-europe