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
| Scope / Tonnage | Final Registration Date | Source |
|----------------|------------------------|--------|
| Newly Placed Substances (Pre-Registration) | Within 30 days from placing on market | Ministry Announcement |
| Lead Company Determination (Existing Substances) | 12/31/2025 | Ministry Announcement |
| Lead Company Determination (New Substances) | Within 6 months from placing on market | Ministry Announcement |
| Provisional Registration (Lead Company) | 03/31/2026 | Ministry Announcement |
| Provisional Registration (Member Companies) | 09/30/2026 | Ministry Announcement |
| 1000t+ and High Hazard Substances (Full Registration) | 12/31/2026 | Ministry Announcement |
| 100t+ Substances (Full Registration) | 12/31/2028 | Ministry Announcement |
| 1t+ Substances (Full Registration) | 12/31/2030 | Ministry Announcement |
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.