Our clients many times consulted us the possibility of a Late pre-registration under the scope of KKDİK after the initial deadline for pre-registration which is 31.12.2020. 

We put forward our opinion based on experience and expertise as the pre-registration will continue for the companies that meets the conditions for Late Pre-registration.  

The initial deadline applies for the substances that were manufactured and imported >1mta before 31.12.2020. But as a reality of the business World there will be substances that are manufactured or imported for the term 2021 – 2023, even there might be new Legal Entities on the scene which were not existing before 31.12.2020. As well there might be substances which were below 1mta before 31.12.2020 but the volume exceeds 1 mta in the term 2021-2023. As the regulations should be giving such flexibility to the industries, there should be an option for the above cases. 

Even though it was not mentioned on the legal text with a definition of ‘’Late Pre-registration’’ the Competent Authority had published an announcement to clarify such questions in mind. 

The below graph is published on the Help Desk web page of MoEU. It clearly states that; the pre-registration (Ön-MBDF) will continue till 31.12.2023. 












Source: Help Desk web page of MoEU.

We are glad that is declared by the Competent Authority which is in line with our comments earlier. 

But also, we still need to consider that Late pre-registration under EU REACH was possible till 6 months before the relevant deadline.  That approach was to give the latest pre-registrants the sufficient time for meeting the 31.12.2023 registration deadline.

Per the above graph pre-registration under the scope of KKDİK is possible till 31.12.2023. But it is a reality that a Late pre-registrant who submits a late pre-registration in November 2023 has almost no possibly to reach the deadline as a co-registrant. Taking this into consideration we advise companies who are in the need of submitting a late pre-registration to take the deadline as September 2023 at the latest to achieve the submission of a co-registration dossier in accordance with the Registration deadline.  

CRAD Team