Importing Fragrance Products into Turkey: KKDIK and Labeling

Turkey operates a chemical regulatory system closely modeled on the European Union’s REACH regulation, but with its own registration portal, timelines, and language requirements. The framework is known as KKDIK, from the Turkish “Kimyasinin Kaydi, Degerlendirilmesi, Izni ve Kisitlanmasi,” established by the Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals published by the Ministry of Environment, Urbanisation and Climate Change. For B2B buyers importing fragrance compounds, essential oils, candles, and diffusers into Turkey, KKDIK creates registration and communication duties that mirror, but are distinct from, EU REACH.

KKDIK and the Registration Threshold

Under KKDIK, any manufacturer or importer of a chemical substance, on its own or in a mixture, at 1 tonne or more per year must register that substance with the Ministry through the Chemical Registration System (KKS, Kimyasal Kayit Sistemi). The 1-tonne threshold is calculated per substance across all imported mixtures, exactly as under EU REACH.

A single fragrance formulation may contain dozens of individual aroma chemicals, and each one is assessed against the threshold. Common fragrance raw materials such as linalool (CAS 78-70-6), limonene (CAS 5989-27-5), and vanillin (CAS 121-33-5) are widely registered, but importers must verify the registration status of every component.

Registration Timelines and Pre-Registration

KKDIK introduced a phased registration schedule. Substances were first subject to a pre-registration (on-kayit) process, followed by full registration deadlines that vary by tonnage band and substance hazard profile. The full registration deadlines run through the late 2020s, with higher-tonnage and more hazardous substances due earlier. Importers should confirm the applicable deadline for each substance and ensure that a complete registration dossier, including a Chemical Safety Report (CSR) where required for substances at 10 tonnes or more per year, is in place.

The Only Representative Route

A non-Turkish manufacturer cannot register directly under KKDIK. Foreign suppliers may appoint an Only Representative (OR, “Tek Temsilci”) established in Turkey to fulfill registration obligations on their behalf, relieving individual Turkish importers of the duty. This mirrors the EU REACH Article 8 model.

For B2B buyers, the practical question is whether the Chinese supplier has appointed a Turkish OR with active registrations covering the relevant substances. If so, the importer can rely on that coverage. If not, the Turkish importer must register the substance itself, which requires a full data package and can be costly and time-consuming.

Safety Data Sheets in Turkish

KKDIK requires Safety Data Sheets (SDS) to be prepared in Turkish, compliant with the Regulation on Safety Data Sheets and aligned to the UN Globally Harmonized System. The SDS must include the registration number for each registered substance, the Turkish supplier or OR details, and full hazard classification and exposure information. A Turkish-language SDS is mandatory for customs clearance and for downstream communication to industrial users.

Consumer Product Labeling

Finished fragrance consumer products must comply with Turkish labeling rules. The Ministry of Trade oversees general product safety and labeling under the Law on Consumer Protection (Law No. 6502) and the Regulation on Labels, Tariffs and Price Tags. Mandatory label information must be in Turkish and typically includes:

• The product name and intended use.
• Net content in metric units.
• The manufacturer or importer name and address in Turkey.
• Country of origin.
• Batch or lot identification.
• Safety warnings and directions for use.

For cosmetic fragrances applied to the body, the Cosmetics Regulation, aligned with EU Regulation EC 1223/2009, requires a full INCI ingredient list, a responsible person in Turkey, a Product Information File (PIF), and notification through the Turkish Cosmetics Notification System (UTS, Urun Takip Sistemi) operated by the Ministry of Health.

Hazardous Substance Communication

Products classified as hazardous must comply with the Regulation on Classification, Labelling and Packaging of Substances and Mixtures (the Turkish CLP equivalent, SEA Yonetmeligi), which mirrors EU CLP Regulation EC 1272/2008. This requires GHS pictograms, signal words, and hazard and precautionary statements in Turkish on both industrial SDS documents and, where applicable, consumer packaging.

Customs and Importer of Record

Imported goods clear Turkish Customs under the correct HS classification, with fragrance compounds under heading 3302, perfumes under 3303, room preparations under 3307, and candles under 3406. The importer of record must be a Turkish entity. Customs may request the Turkish-language SDS and evidence of KKDIK registration before release, so documentation must be ready before shipment.

Practical Compliance Checklist

1. Obtain a full CAS-level ingredient disclosure from your supplier.
2. Verify each substance against the Turkish chemical inventory and KKDIK registration status.
3. Confirm whether the supplier has a Turkish Only Representative or whether you must register as importer.
4. Secure Turkish-language SDS documents with registration numbers for every product.
5. Prepare Turkish consumer labels with all mandatory fields and safety warnings.
6. For body-applied fragrances, complete UTS cosmetic notification and maintain a Product Information File.
7. Keep registration and notification evidence on file for customs and market surveillance.

How Aromiso Supports Turkish Buyers

Aromiso provides Turkish importers with complete ingredient disclosures, CAS-level composition statements, and SDS documentation that can be localized into Turkish. We work with buyers to identify which substances require KKDIK registration and can coordinate with appointed OR partners to streamline coverage. For cosmetic-category products, we supply the technical specifications needed for UTS notification and the Product Information File.

KKDIK gives Turkey a REACH-equivalent regime with its own portal and language rules. With accurate ingredient data, Turkish-language documentation, and clear registration coverage, fragrance brands can enter the Turkish market efficiently, and Aromiso treats KKDIK readiness as a standard part of its export support for the region.