What’s happening?

What’s happening? Here is an update for October 2025:

PFAS: update on the EU universal restriction
KKDIK: Türkiye publishes finalised principles and procedures

PFAS: update on the EU universal restriction

On 20 August 2025, the European Chemicals Agency (ECHA) published the updated proposal to restrict per- and polyfluoroalkyl substances (PFAS) under EU REACH, which was submitted by the five National Authorities (Dossier Submitter).

The restriction proposal was originally submitted to ECHA in 2023 and aims to reduce PFAS emissions into the environment.

Following formal consultation in 2023 and heated debates among industry, the initial restriction proposal was updated to account for over 5,600 scientific and technical comments from third parties and newly gathered evidence.

In addition to the restriction update from the Dossier Submitter, the evaluation of the Committee for Risk Assessment (RAC) and Committee for Socio-Economic Analysis (SEAC) was carried out in batches, focusing on the 14 different sectors analysed in the original restriction proposal, as well as PFAS manufacturing and horizontal issues.

These original sectors are:

ski wax
consumer mixtures and miscellaneous consumer articles
cosmetics
metal plating and manufacture of metal products
food contact materials and packaging
textiles, upholstery, leather, apparel and carpets (TULAC)
petroleum and mining
construction products
applications of fluorinated gases
transport
energy
medical devices
lubricants, and
electronics and semi-conductors

For more information, read the H2 Compliance article.

KKDIK: Türkiye publishes finalised principles and procedures

On 12 August 2025, the Turkish Ministry of Environment, Urbanization and Climate Change released the finalised principles and procedures for the Turkish REACH Regulation (KKDIK).

This long-awaited update introduces several important changes that impact how companies manufacture, import and register chemical substances in Türkiye.

Alignment and clarity

The KKDIK Regulation aims to align national chemical management with EU REACH standards, and this latest publication provides much-needed clarity on registration processes, deadlines and compliance expectations.

Key changes include:

Pre-registration

The updated deadline is 31 October 2025. Pre-registration is essential for joining the Substance Information Exchange Forum (SIEF) and progressing toward full registration.

For substances already on the market, a Lead Registrant must be appointed by 31 December 2025 to coordinate data sharing and submit the joint registration dossier.

While selection is voluntary, if no company steps forward, the Ministry may appoint one based on tonnage band, available data and company size.

Temporary registration

This is a newly introduced compliance pathway for companies unable to submit full registration dossiers by the initial deadlines. It allows continued market access while full registration is prepared.

The deadlines for temporary registrations are 31 March 2026 for Lead Registrants and 30 September 2026 for member registrants.

Safety Data Sheets (SDS)

Uploads to the Ministry’s designated SDS software platform become mandatory.

What does this mean for businesses?

If you are producing or importing chemicals into Türkiye, these changes may affect your registration strategy, timelines and data requirements.

It is essential to:

Review your substance inventory and registration status
Determine whether full or temporary registration is appropriate
Ensure SDS are compliant and uploaded correctly, and
Monitor updates from the Ministry and advisory groups

H2 Compliance experts can guide you through the updated KKDIK requirements, assist with registration planning, and ensure your compliance strategy is aligned with the latest developments.

Please contact them here.