KKDIK Registration Timeline: Ministry Reminds Critical Deadlines

KKDIK Registration Timeline: Ministry Reminds Critical Deadlines

The Ministry of Environment, Urbanization and Climate Change (General Directorate of Environmental Management), in its official letter dated 11.12.2025, reminded the critical deadlines for chemical substance registration obligations under KKDIK. The letter emphasizes that companies must fulfill their obligations on time and the process must be followed meticulously according to the timeline updated on August 5, 2025.

Key Dates

1. Pre-Registration for Newly Placed Substances

Deadline: Within 30 days from the date of placing on the market

Pre-registration for newly placed substances must be completed within 30 days from the date of placing on the market.

2. Lead Company Determination

For Existing Substances: December 31, 2025

The lead company determination process for existing substances must be completed by December 31, 2025. This date is critical for establishing joint registration groups and coordination mechanisms.

For Newly Placed Substances: Within 6 months from the date of placing on the market

Lead company determination for newly placed substances must be made within 6 months from the date of placing on the market.

3. Provisional Registration Processes

Lead Company Provisional Registration: March 31, 2026

In cases where the full registration dossier cannot be prepared, the deadline for provisional registration applications for lead companies is March 31, 2026.

Member Company Provisional Registration: September 30, 2026

The deadline for provisional registration applications for joint registration group members is September 30, 2026.

4. Full Registration Deadlines (Tonnage/Hazard Based)

December 31, 2026 - For substances meeting the following conditions:

1. Substances manufactured or imported on their own, in mixtures, or in articles in quantities of 1000 tons or more per year

2. Substances manufactured or imported on their own, in mixtures, or in articles in quantities of 100 tons or more per year and classified as Aquatic Acute 1 and/or Aquatic Chronic 1 (H400, H410) according to SEA Regulation

3. Substances manufactured or imported on their own, in mixtures, or in articles in quantities of 1 ton or more per year and classified as carcinogenic, mutagenic, and/or toxic to reproduction Category 1A or 1B according to SEA Regulation

December 31, 2028 - 100 Ton and Above Substances

Full registration deadline for substances manufactured or imported on their own, in mixtures, or in articles in quantities of 100 tons or more per year is December 31, 2028.

December 31, 2030 - 1 Ton and Above Substances

Final registration deadline for substances manufactured or imported on their own, in mixtures, or in articles in quantities of 1 ton or more per year is December 31, 2030.

Registration Timeline Summary Table

Pier Compliance Commentary

In the field, it is observed that some companies have not completed pre-MBDF/MBDF steps after October 31. Therefore, both the clearer definition of processes in KKS and the emphasis on "pre-registration/pre-MBDF, MBDF communication and lead selection" steps in the reminder letter indicate that the process is actually intended to be accelerated. The message is clear: The timeline will be applied and compliance with registration dates will be expected.

Critical Steps for Importers and Manufacturers

In KKDIK, risk does not only occur on the final registration day; it grows in accumulated delays in intermediate steps such as lead company selection, MBDF communication, provisional registration planning, and dossier preparation. Therefore, companies must:

1. Substance Portfolio and Tonnage Verification: CAS/EC numbers, annual tonnages, and use areas of all substances must be determined and verified.

2. Role and Responsibility Clarification: Manufacturer/importer/OR (Only Representative) roles must be clarified and responsibilities determined.

3. Joint Registration Strategy: Lead/member strategy must be managed from today, and joint registration groups must be coordinated.

4. Pre-MBDF/MBDF Organization: Pre-MBDF and MBDF communication processes must be completed.

5. Provisional Registration Scenario: A provisional registration plan must be made for cases where the full registration dossier cannot be prepared.

6. Full Registration Roadmap: Full registration preparations must be initiated according to tonnage and hazard class.

Pier Compliance Support

As Pier Compliance, we accelerate your timeline compliance by establishing end-to-end pre-MBDF/MBDF organization, lead/member strategy, provisional registration scenario, and full registration roadmap. Contact us to advance without risking your KKDIK obligations.

Contact us for a free preliminary assessment. You can reach us through piercompliance.com or directly consult with our expert team.