What You Need to Know About Buying and Selling Fragrance Oils Under KKDİK (Turkish REACH)

When a top note fades, an underlying layer takes the stage. In fragrance oil trade, too, there is an invisible yet decisive layer: regulation. Its name is KKDİK.

KKDİK is the acronym for "Kimyasalların Kaydı, Değerlendirilmesi, İzni ve Kısıtlanması Hakkında Yönetmelik" — the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals. Turkey's counterpart to the European Union's REACH regulation, KKDİK was published in the Official Gazette No. 30105 on 23 June 2017 and entered into force on 23 December 2017. For this reason, the industry commonly refers to it as "Turkish REACH".

Its purpose is clear: to establish the administrative and technical procedures governing the registration, evaluation, authorisation and restriction of chemicals — with the aim of ensuring a high level of protection for human health and the environment, promoting alternative methods for assessing the hazards of substances, and enhancing competitiveness and innovation.

So why does this concern you? Because what we call fragrance oils, perfumery raw materials and aromatic compounds are, in legal terms, chemical substances or mixtures. The romantic world of scent is written, on the shelf below, in the dry language of chemistry. The rest comes down to your diligence.

The regulation's first question is straightforward: where do you stand in this supply chain? Your obligations change with your role.

KKDİK treats the manufacturer and importer of a substance as the primary obligated parties. Under KKDİK, while substance manufacturers and importers bear direct obligations, a mixture formulator is assessed according to their position in the chain. If you are bringing a ready-made fragrance oil in from abroad, the registration responsibility falls squarely on you.

The overseas producer is not directly accountable. A company not established in Turkey has no direct obligations under the KKDİK Regulation; the obligation to comply rests with the companies importing from abroad. This is where the "only representative" mechanism comes into play — a representative appointed within Turkey by a foreign manufacturer to fulfil obligations on their behalf.

KKDİK operates on a phased schedule. As tonnage increases, deadlines move closer. The timeline was revised in 2025, so anyone who planned around the old dates needs to update their roadmap.

Under the revised schedule published on 5 August 2025, timely fulfilment of obligations is essential. One significant practical change: owing to difficulties encountered in identifying lead registrants, it has been decided that provisional registration processes may also be conducted on an individual basis — individual provisional registration dossiers are to be submitted through the Ministry's Chemical Registration System (KKS) with a clearly stated justification.

These dates are a moving target and may be revised through advisory group meetings. Use the figures in this article as a roadmap, but always verify your exact compliance deadline against the current official source.

Regulation can seem abstract; in practice, however, it is a sequential workflow. Let us bring the process down to ground level for a company buying and selling fragrance oils.

Regulation is not a labyrinth — it simply has no patience for impatience. The most common error is confusing registration with safety standards.

The most critical conceptual distinction is this: KKDİK ≠ IFRA. KKDİK is a government regulation governing the lawful placing of a substance on the Turkish market. IFRA is an industry standard that sets safe use levels for fragrance materials. KKDİK registration does not imply IFRA compliance; the two serve entirely different purposes. (Our articles "What Are IFRA Standards?" and "IFRA Certificate vs IFRA Compliance" explain this distinction in detail.)

Also bear in mind that IFRA limits are set not against the total fragrance oil percentage but against individual substances/allergens within the fragrance oil and the product category (leave-on vs rinse-off). Generalisations such as "all fragrance oils are permitted up to 20%" are incorrect; you must read the IFRA compliance statement for each product.

There is also a further distinction on the cosmetics side. If you intend to place a finished perfume or cosmetic product on the market, separate obligations — such as ÜTS (Product Tracking System) registration — come into play alongside KKDİK. (Our article "ÜTS Registration: What to Do Before Selling Cosmetic Perfumes" covers this in full.)

And the rules carry real enforcement. The sale, import or use of unregistered chemical substances on the Turkish market is prohibited. Companies that fail to complete the required KKDİK registrations on time may face significant administrative fines.