KKDİK Process in the Paints and Coatings Sector and the 30 September 2026 Deadline

One of the fundamental regulations governing chemical management in Turkey, the KKDIK Regulation, has become a critical compliance area particularly for sectors working with chemical substances, mixtures and product formulations. The paints and coatings sector is among those most directly affected by this regulation. This is because the sector uses numerous substances and mixtures such as pigments, resins and solvents in its supply chain.

Following recently published Procedures and Principles and Ministry announcements in Turkey, companies have entered a unique implementation phase. In this new period, it is not sufficient for companies merely to know of the existence of registration obligations; they must also correctly determine which registration pathway to follow for which substances, which actor is responsible, and which procedures must be completed by 30 September 2026.

Why is KKDIK Important for the Paints and Coatings Sector?
Paints and coatings products typically consist of mixtures of multiple chemical substances. Under KKDIK, registration obligations are evaluated based not on the commercial name of the product, but on the substances contained within it. For this reason, in assessing a paint, varnish, coating, primer, ink or surface treatment product under KKDIK, the substances it contains must first be identified.

Generally under KKDIK, substances manufactured or imported in Turkey in quantities of 1 tonne or more per year are subject to registration obligations. These substances may exist on their own, within mixtures, or under certain conditions within articles. The most common scenario in the paints and coatings sector is substances being imported into Turkey as mixtures or being used in formulation production in Turkey.

At this point, the following companies may face KKDIK obligations:

-Paints and coatings manufacturers established in Turkey,
-Companies importing chemical substances or mixtures into Turkey,
-Manufacturers established abroad and supplying products to Turkey,
-Foreign suppliers wishing to protect their importers in Turkey under KKDIK,
-Suppliers of resins, pigments, solvents, additives or intermediate products.

For companies established abroad, the important point is that KKDIK obligations can be fulfilled through a Single Representative established in Turkey. In this case, importers in Turkey can be included in the relevant registration scope.

Why is 30 September 2026 Critical?
An important flexibility in the KKDIK registration process was provided through an announcement made by the Ministry in March 2026. The primary purpose of this announcement is to establish Turkey's national chemical inventory and ensure all companies within scope are included in the system.

In this context, all substances subject to KKDIK must obtain a registration number by 30 September 2026. This registration number may be under provisional or full registration. In other words, it is not sufficient for only the Lead Registrant to have completed full registration; member registrants must be properly defined in the system. The basic principle at this stage can be regarded as "No data, no market". Substances without registration numbers may create serious compliance risks after 30 September 2026.

How is the Registration Pathway Determined?
Under KKDIK, companies essentially have two pathways: joint registration or individual provisional registration. In the joint registration pathway, there is one Lead Registrant for the same substance and other companies participate as member registrants. In this case, a Letter of Access must be obtained, the company must prepare its own file and complete the registration process.
However, in practice, a Lead Registrant may not have been appointed for every substance. Even if a Lead has been appointed, the LoA process may not have started or proceeding via joint registration may not be feasible in terms of timing. In such cases, individual provisional registration offers a practical alternative for companies.

Individual provisional registration may be considered in the following situations:

-If no Lead Registrant has been appointed for the substance,
-If the Lead Registrant has not completed the registration process,
-If LoA is not yet available,
-If the company does not wish to participate in the LoA process (with justification),
-If the company prefers to first perform individual provisional registration and later transfer to joint registration.

What Information is Important in the Provisional Registration Process?
Provisional registration, while not requiring data as comprehensive as full registration, requires the file to contain certain basic information. Among the main sections appearing in the KCS/IUCLID file are substance identity, composition, analytical information, importer information, GHS classification, use and exposure information, estimated quantities, mixture information, physico-chemical properties and safety data sheet.

For the paints and coatings sector, the following information will be particularly critical:

-Substance identity and EC/CAS information,
-Substance composition and purity information,
-Analytical data or justification for its absence,
-Information on importers in Turkey,
-Annual tonnage range,
-Purpose of substance use in paints or coatings products,
-Function within the mixture,
-Classification and labelling information,
-Safe use conditions.

While full data requirements based on tonnage are not required at the provisional registration stage, justification may be needed for certain information not provided in the file. Additionally, for paint, coating or raw material manufacturers established abroad, the Single Representative must submit importer information in Turkey to the KKDIK system. Importers in Turkey must also have a UCTS account. The information in question may be verified in inspections regarding registration number and importer matching.

Inspection Risk After 1 October 2026
Inspections are expected to begin as of 1 October 2026. These inspections may be conducted at the customs stage or as facility inspections. Unregistered substances may be detained at customs, may be treated as non-compliance in facility inspections, may result in administrative penalties or may not be placed on the market.

For this reason, substance inventory completion and registration strategy clarification must be done before approaching 30 September 2026. For companies operating in the paints and coatings sector, the KKDIK process can be managed through the following steps:

-Preparation of product and raw material inventory,
-Conducting KKDIK scope assessment for each substance,
-Clarification of supply chain role,
-Determination of registration pathway for each substance,
-Preparation of importer and use information,
-Preparation of appropriate justifications for missing data fields,
-Obtaining registration number before 30 September 2026.

During this period, companies must review their substance inventories, confirm registration status with suppliers, correctly identify importers in Turkey and develop appropriate registration strategies for each substance. Joint registration processes should be evaluated where possible, but if there is uncertainty in the Lead Registrant or LoA process, individual provisional registration option should be planned in a timely manner.

Chemleg Turkey: www.chemleg.com

Chemleg Europe: www.chemleg.nl