The Turkey REACH (KKDIK) was published by the Ministry of Environment and Urbanization of the Turkish Republic on June 23, 2017, and formally came into effect on December 23, 2017.
Under the KKDIK, companies are required to pre-register and register substances that are manufactured or placed on the Turkish market either on their own, or in mixtures or in articles with an intended release which are equal to, or above, 1 metric ton per annum. Companies exporting chemicals to Turkey may appoint an Only Representative (OR) to submit the KKDIK registration and the CLP notification on their behalf.
The deadline for pre-registration is December 31, 2023, which means chemical products without a registration number cannot legally enter the Turkey market from January 1, 2024. Similar to EU REACH, Turkey will collect an administrative fee for KKDIK registration. The administrative fees vary based the tonnage bands as well as the scale of enterprises.
However, the Turkish government increased the administrative fees on January 12, 2023. See details below:
Table 1: Standard Fees
| Individual Submission | Joint Submission (TRY) | |
| Fee for Substances between 1-10 tonnes | 2200 | 1660 |
| Fee for Substances between 10-100 tonnes | 5500 | 3880 |
| Fee for Substances between 100-1000 tonnes | 15500 | 11100 |
| Fee for Substances more than 1000 tonnes | 33300 | 26600 |
Table 2: Reduced Fees for SMEs
|
Medium-sized Enterprises |
Medium-sized Enterprises (Joint submission) (TRY) |
Small-sized Enterprise (Individual submission) (TRY) |
Small-sized Enterprise (Joint submission) (TRY) |
Micro-sized Enterprise (Individual submission) (TRY) |
Micro-sized Enterprise (Joint submission) (TRY) |
|
| Fees for Substances between 1-10 tonnes | 1100 | 660 | 550 | 330 | 220 | 110 |
| Fees for Substances between 10-100 tonnes | 3300 | 2000 | 1660 | 1000 | 440 | 220 |
| Fees for Substances between 100-1000 tonnes | 8800 | 4400 | 3300 | 2200 | 880 | 330 |
| Fees for Substances more than 1000 tonnes | 22200 | 11100 | 9400 | 6600 | 2200 | 1100 |
Previously, the administrative fees were as follows:
Table 1. Standard Fees
| Individual Submission (TRY) | Joint Submission (TRY) | |
| Fee for Substances between 1-10 tonnes | 1000 | 750 |
| Fees for Substances between 10-100 tonnes | 2500 | 1750 |
| Fees for Substances between 100-1000 tonnes | 7500 | 5000 |
| Fees for Substances more than 1000 tonnes | 15000 | 12000 |
Table 2. Reduced Fees for SMEs
| Medium-sized Enterprises (Individual submission) (TRY) |
Medium-sized Enterprises (Joint submission) (TRY) |
Small-sized Enterprise (Individual submission) (TRY) |
Small-sized Enterprise (Joint submission) (TRY) |
Micro-sized Enterprise (Individual submission) (TRY) |
Micro-sized Enterprise (Joint submission) (TRY) |
|
| Fees for substances between 1-10 tonnes | 500 | 300 | 250 | 150 | 100 | 50 |
| Fees for substances between 10-100 tonnes | 1500 | 900 | 750 | 450 | 200 | 100 |
| Fees for substances between 100-1000 tonnes | 4000 | 2000 | 1500 | 1000 | 400 | 150 |
| Fees for substances more than 1000 tonnes | 10000 | 5000 | 4250 | 3000 | 1000 | 500 |
It is obvious that the administrative fee has significantly increased, by more than 100%.
With the pre-registration deadline for KKDIK quickly approaching on the 31st of December 2020, we warmly reminds you that enterprises must strive to complete KKDIK registration before the registration deadline to trade smoothly with Turkey. As non of the enterprises has completed the full registration under KKDIK, related enterprises may register as a lead registrant to take the trade initiative.
