KKDIK vs EU REACH, Differences That Matter to Exporters

KKDIK is often called "Turkey REACH", and the label is fair as far as the text goes. Article 65 of KKDIK states that it was prepared with EU REACH, Regulation (EC) No 1907/2006, in mind, and most articles map one to one. The procedures, deadlines, IT system and SDS rules are Turkish, however, and an EU registration does not carry over. This article compares the two and answers the question we hear most from EU manufacturers: can we reuse our REACH data?

KKDIK and EU REACH compared

Where KKDIK follows REACH closely

The scope, exemptions and data requirements are essentially the same. Polymers are exempt, but monomers above the 2% threshold must be registered. Isolated intermediates have reduced requirements. Registration data increase with tonnage, and the KKDIK annexes mirror REACH. KKDIK Annex 7 corresponds to REACH Annex VII, Annex 8 to VIII, and so on to Annex 10. A chemical safety report is required from 10 tonnes per year, and exposure scenarios are attached to the SDS.

The principle of "one substance, one registration" also applies. All registrants of a substance share data through the forum, and one lead registrant submits the joint part of the dossier. A registrant can opt out of parts of the joint submission only on grounds that match REACH Article 11(3): disproportionate cost, confidentiality, or disagreement on data selection.

Authorisation and restriction follow the REACH model too. KKDIK Annex 17 carries restrictions that track the REACH Annex XVII entries, many with Turkish application dates set in Article 66 of KKDIK.

Where KKDIK differs in practice

The timetable

The EU finished its phase-in registrations in 2018. Turkey is in the middle of its process, with full registration deadlines on 31 December 2026, 2028 and 2030. The first band covers substances at 1,000 tonnes or more per year, substances at 100 tonnes or more classified Aquatic Acute 1 or Chronic 1, and CMR Category 1A or 1B substances at 1 tonne or more. The details are in our article on KKDIK registration deadlines.

Temporary registration

KKDIK added a step REACH never had. A lead registrant could make a temporary registration with a basic data set by 31 March 2026, and members, or companies filing individually, had to follow by 30 September 2026. The full dossier is still due by the band deadline. The Ministry now checks for temporary or full registration numbers.

The only representative must be in Turkey

An EU only representative has no standing under KKDIK. If you want one registration covering all your Turkish customers, you need a KKDIK only representative established in Turkey. Otherwise each Turkish importer registers separately.

Certified experts for SDSs and dossiers

The Chemical Assessment Expert (KDU) has no EU counterpart. Under Article 27 of KKDIK, only a KDU certified under Annex 18 may prepare an SDS for the Turkish market, and the registration dossier carries a KDU review statement. Since 31 December 2023, when the old Turkish SDS regulation was repealed, this rule applies to every new or revised SDS. See our page on the Turkish SDS under KKDIK.

Classification gaps

The most recent SEA amendment we could confirm, aligning it with CLP, dates from December 2020. EU changes since then, including the new hazard classes for endocrine disruptors, PBT and vPvB, and PMT and vPvM added by Delegated Regulation (EU) 2023/707, had not, as far as we could confirm, been transposed into the SEA regulation as of October 2026. An EU SDS can therefore carry hazard statements that have no Turkish legal basis, and a classification review is needed when preparing the Turkish version.

Can EU REACH data be reused for KKDIK

Usually, yes, in a technical sense. Whether you can use it legally depends on who owns it and what your licence says.

KKDIK data requirements are the same as REACH, so the studies in an EU dossier normally meet Turkish requirements for the same tonnage band. The dossier structure in KKS follows IUCLID sections, which makes transfer of the technical content easier. Use descriptors, classification and the chemical safety assessment can also be reused, with Turkish uses and exposure conditions checked.

The legal question has three parts.

1. Do you own the data? If your company generated the studies, you can use them in Turkey. You may also be asked to share them in the MBDF, against cost compensation, if you hold data others need.
2. Is your EU letter of access limited to the EU? Most consortium LoAs grant the right to refer to the data for EU REACH registration only, sometimes EEA. Using the same studies for KKDIK needs a separate licence, often called a Turkey extension or KKDIK LoA. Some EU consortia offer these directly, others license the data to the Turkish lead registrant instead.
3. Who is the Turkish lead registrant, and what did they buy? If the Turkish lead has already licensed the EU data for Turkey, members buy a Turkish LoA from the lead and do not need to deal with the EU consortium. If the lead used different data, an EU registrant that submits its own data has to justify an opt-out under Article 12(3).

The cost-sharing framework also differs. In the EU, Implementing Regulation (EU) 2016/9 sets detailed data and cost-sharing rules. In Turkey, the Procedures and Principles of August 2025 set lead registrant selection and data transfer rules, while cost sharing relies more on the forum's own agreement.

A practical sequence for EU registrants entering Turkey

1. Map EU registrations to Turkish exports: which registered substances reach Turkey, at what volume, and through which importers.
2. Decide between an only representative and importer registrations, taking the combined tonnage into account.
3. Check the Turkish pre-registration and temporary registration status for each substance.
4. Read your EU LoAs for territorial scope, and ask the consortium whether a Turkey extension exists.
5. Contact the Turkish lead registrant for KKDIK LoA terms and compare the two routes.
6. Prepare the Turkish member dossier and a KDU-prepared Turkish SDS that matches it.

Steps 4 and 5 are where most of the money is decided. A Turkey extension of an EU LoA and a Turkish LoA from the local lead registrant can differ considerably in price and in the data they cover, so it pays to get both offers in writing before committing. Our KKDIK registration service handles these steps from Turkey, in Turkish, with reporting in English.