Safety Data Sheets (SDS) are one of the main tools for communicating the hazards of chemical substances and mixtures and providing information on their safe handling, storage, transport and use.

In Türkiye, companies that manufacture, import or market chemical products must comply with a specific regulatory framework combining requirements for the registration, evaluation, authorisation and restriction of chemical substances with specific obligations for preparing and supplying Safety Data Sheets.

The Turkish framework is closely related to European chemicals legislation, but it should not be treated as a simple extension of REACH and CLP.

The main legislation governing the registration, evaluation, authorisation and restriction of chemical substances in Türkiye is KKDIK, while specific SDS requirements are established by Turkish rules on the preparation and distribution of Safety Data Sheets for hazardous substances and mixtures.

The Turkish system also incorporates the principles of the Globally Harmonized System (GHS) for hazard classification and communication.

This combination of requirements can be particularly relevant for international companies. An SDS prepared for the European Union market may provide much of the technical information needed, but it should not automatically be used in Türkiye without checking Turkish regulatory requirements.

Contents

• Summary
• Which regulations govern SDS in Türkiye?
• What is KKDIK?
• How are KKDIK and REACH related?
• How is the GHS applied in Türkiye?
• When is an SDS mandatory in Türkiye?
• What information must an SDS in Türkiye contain?
• Who can prepare an SDS in Türkiye?
• What obligations do manufacturers, importers and suppliers have?
• When must an SDS in Türkiye be updated?
• What labelling requirements apply?
• Can a European SDS be used in Türkiye?
• Recent regulatory changes
• Common mistakes when preparing an SDS for Türkiye
• SDS compliance checklist for Türkiye
• How to keep SDS compliant in Türkiye
• Frequently asked questions about SDS in Türkiye
• Conclusion
• How can ExESS help?

Summary

In Türkiye, Safety Data Sheets are governed by a chemicals framework closely related to the European model but with its own national requirements.

The main chemicals management framework is the KKDIK Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals, published in the Turkish Official Gazette in 2017. The regulation establishes Türkiye’s system for the registration, evaluation, authorisation and restriction of chemical substances and contains, in Annex 2, the requirements for preparing Safety Data Sheets. Official Turkish sources continue to identify KKDIK as the framework applicable to chemical substances and mixtures marketed in Türkiye.

Türkiye also has specific rules on Safety Data Sheets for hazardous substances and mixtures. Therefore, checking that an SDS was prepared in accordance with EU REACH and CLP is not enough to determine whether it complies in Türkiye.

A particularly important point for international companies is that KKDIK should not simply be understood as a copy of REACH. Although the two frameworks are conceptually closely aligned, obligations must be assessed against the Turkish regulatory text and national procedures.

Turkish authorities also use specific systems to record information about substances and mixtures. The Turkish Ministry’s latest official environmental report states that SDS for hazardous substances and mixtures are uploaded to and registered in the Ministry’s system.

Which regulations govern SDS in Türkiye?

The regulatory framework should be considered through three main instruments:

• KKDIK, which establishes the general framework for chemicals management.
• The SEA Regulation, which sets Türkiye’s rules for the classification, labelling and packaging of substances and mixtures.
• The specific Safety Data Sheet rules, which set the requirements for preparing and supplying SDS.

This distinction matters because each instrument serves a different purpose.

KKDIK governs matters such as the registration, evaluation, authorisation and restriction of substances. Its Annex 2 sets out the requirements for compiling SDS. Official Turkish Ministry sources expressly refer to this Annex when discussing SDS preparation.

The SEA Regulation establishes Türkiye’s system for classifying, labelling and packaging substances and mixtures. The Turkish Ministry maintains a classification and labelling inventory associated with this regulation.

The SDS must reflect the outcome of this regulatory assessment. Classification and SDS should therefore be managed as related parts of the same process.

What is KKDIK?

KKDIK is the acronym used for Türkiye’s Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals.

The regulation was published in Official Gazette No. 30105 on 23 June 2017 and is one of the pillars of Türkiye’s chemicals management system.

It aims to establish a system to:

• register substances
• evaluate their risks
• control substances presenting certain hazards
• establish authorisation requirements
• apply restrictions
• improve the information available on chemical substances
• protect human health and the environment

For companies marketing chemical products, this means that SDS compliance cannot be considered in isolation.

Composition and hazard information used to comply with KKDIK may directly affect safety documentation.

KKDIK and SDS

Annex 2 to KKDIK contains the requirements for compiling Safety Data Sheets.

A company preparing an SDS for Türkiye must therefore check both the document-specific requirements and the regulatory information supporting its content.

This includes, among other things:

• substance and mixture identification
• composition
• classification
• health hazards
• physical hazards
• environmental hazards
• toxicological information
• protective measures
• transport information
• regulatory information

A change to information about a substance may affect several of these elements at the same time.

How are KKDIK and REACH related?

KKDIK is strongly inspired by the European chemicals management system.

It is therefore commonly referred to informally as “Turkish REACH”.

This comparison can help explain the system, but it should be used with caution.

KKDIK and REACH share concepts such as:

• registration
• evaluation
• authorisation
• restrictions
• substances of very high concern
• information throughout the supply chain
• risk-based management

However, the legal obligations applicable in Türkiye must be checked under KKDIK and related Turkish legislation.

What does this mean for SDS?

A European company that already has an SDS compliant with REACH can reuse much of the existing information.

However, this does not mean that it can simply copy the European document and use it in Türkiye.

Among other things, the company must check:

• the classification applicable in Türkiye
• SEA Regulation requirements
• specific SDS requirements
• regulatory information
• language
• supplier details
• requirements arising under KKDIK

The same substance may be used in an EU SDS and a Turkish SDS, but the final document must meet the requirements of the jurisdiction where the product is marketed.

How is the GHS applied in Türkiye?

Türkiye’s hazard classification and communication system is based on the principles of the Globally Harmonized System (GHS).

The classification of a substance or mixture is the starting point for determining the information that must be communicated on the label and in the SDS.

The system can be summarised as:

Composition → classification → hazard communication → label + SDS

This relationship is essential for avoiding inconsistencies.

For example, if a change in composition causes a mixture to move into a different hazard category, the label should not be the only item updated. The impact on the SDS and any other safety documentation must also be assessed.

SEA Regulation

The SEA Regulation is Türkiye’s framework for classifying, labelling and packaging substances and mixtures.

The Turkish Ministry maintains an information system relating to substance classification and labelling under this regulation.

For companies, this means that an SDS for Türkiye must be based on a classification compatible with the Turkish framework.

A European CLP classification can serve as a technical reference, but it must be checked before being used directly for the Turkish market.

When is an SDS mandatory in Türkiye?

The obligation to provide an SDS depends on whether the substance or mixture falls within the cases set out in the applicable Turkish regulations.

In practice, companies should first determine:

• which product they are marketing
• its composition
• how it is classified
• whether it falls within a case requiring an SDS
• who must receive it
• what information it must contain

The SDS must be provided to the relevant recipients in the supply chain when the conditions set out in the regulations are met.

This makes it particularly important to keep product classification and databases up to date.

Not all SDS are generated in the same way

A company may have products that:

• require an SDS
• require an SDS because of their classification
• must have safety information even if they are not classified in the same way
• are subject to additional requirements because they contain certain substances

For this reason, it is not advisable to use a simplified rule such as:

“All chemical products need exactly the same SDS.”

The obligation must be determined based on the product and its regulatory status.

Practical example

A European company manufactures a mixture classified as hazardous and also markets it in Türkiye.

The company already has an SDS compliant with REACH and CLP.

The right process is not simply to translate that SDS into Turkish.

The company must check:

composition → Turkish classification → SDS requirements → regulatory information → final document

If the classification or any regulatory data changes, the Turkish SDS must reflect the change.

This approach is particularly important for companies with large product portfolios, because a single change may affect many formulations.

What information must an SDS in Türkiye contain?

The SDS must provide enough information to identify the product, understand its hazards and determine the measures needed for safe handling.

Annex 2 to KKDIK sets out the requirements for compiling SDS. The structure is based on the 16 sections used internationally for Safety Data Sheets. (webdosya.csb.gov.tr)

The sections are:

1. Identification of the substance/mixture and of the company/undertaking
2. Hazards identification
3. Composition/information on ingredients
4. First-aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information

The 16-section structure makes SDS easier to compare internationally, but it does not mean that an SDS prepared for any jurisdiction can automatically be used in Türkiye.

1. Product and supplier identification

Section 1 must allow the substance or mixture and the responsible supplier to be identified unambiguously.

Relevant details may include:

• product identifier
• trade name
• identified uses
• uses advised against
• supplier information
• contact details
• emergency information

The information must be consistent with the label and with the data used in the company’s other regulatory systems.

2. Hazards identification

This section must reflect the classification applicable to the product.

Hazard communication elements must be consistent with the classification and the information used on the label.

A discrepancy between the classification, label and SDS can create both compliance and safety issues.

3. Composition/information on ingredients

For substances and mixtures, the SDS must provide the information needed to understand the hazards associated with relevant ingredients.

Managing this section requires particular care when there are many formulations.

A change in the concentration of an ingredient may affect the mixture’s classification and therefore other SDS sections.

Who can prepare an SDS in Türkiye?

This is one of the aspects that distinguishes Türkiye from many other markets and deserves particular attention.

Turkish regulations set specific requirements for people who prepare SDS.

Certain SDS must be prepared by people who meet the qualification requirements established by Turkish law.

In this context, the term GBF SDS preparation expert qualification certificate is used.

An international company should therefore not assume that anyone who prepares SDS for other markets can automatically prepare SDS for the Turkish market.

What does this mean for companies?

A company must ensure that SDS requiring preparation by a qualified professional are prepared or approved in accordance with the applicable Turkish requirements.

This is particularly important for international manufacturers that outsource SDS preparation.

It is not enough to check that the provider uses a GHS-compatible SDS template.

The applicable professional and regulatory requirements in Türkiye must also be checked.

Internal management and regulatory responsibility

Even when a company uses software to generate SDS, the software does not replace the organisation’s regulatory responsibilities or the professional requirements established for preparing certain documents.

A system can automate calculations, phrase selection, classification, translation and document generation, but the company must establish processes to ensure that its SDS comply with Turkish regulations.

What obligations do manufacturers, importers and suppliers have?

Responsibilities depend on a company’s position in the supply chain.

Manufacturers and importers

Manufacturers and importers must have sufficient information about the substances and mixtures they market.

Relevant tasks include:

• identifying the composition
• assessing hazards
• determining the classification
• checking registration obligations where applicable
• preparing SDS or ensuring that they are prepared
• providing the necessary information to recipients
• keeping documentation up to date

Information used for compliance with KKDIK, the SEA Regulation and SDS requirements must remain consistent.

Suppliers

Suppliers must ensure that the relevant safety information accompanies the product when regulations require an SDS.

Preparing an SDS once is not enough.

A system must ensure that customers receive the correct, current version.

Responsibility for information

A company marketing a product must be able to demonstrate where the information used for its classification and documentation came from.

This is particularly important when:

• the composition changes
• new raw materials are introduced
• a substance’s classification changes
• new toxicological information becomes available
• regulations change

When must an SDS in Türkiye be updated?

An SDS must be updated when relevant new information affecting product safety becomes available or when regulatory circumstances determining its content change.

Common triggers include:

• changes in composition
• changes in classification
• new hazard information
• new toxicological data
• new ecotoxicological data
• changes in physical or chemical properties
• changes in applicable restrictions
• changes to regulatory information
• changes to supplier details

Example: a formulation change

Suppose a manufacturer changes a mixture and increases the concentration of a hazardous ingredient.

The process should not be limited to updating the formula in the production system.

An impact assessment should be carried out:

New formulation → new assessment → possible change in classification → label review → SDS review → new version

If the change does not affect the classification, it may not be necessary to change every hazard communication element. However, a documented process must be in place to determine this.

Version control

A company marketing chemical products in Türkiye should be able to identify:

• the current SDS version
• the issue date
• the revision date
• the reason for the change
• the affected product
• the person or system responsible for the change

This control is particularly important when the same product is marketed simultaneously in Türkiye and other markets.

What labelling requirements apply?

Labelling is closely linked to classification and the SDS.

The SEA Regulation establishes Türkiye’s framework for classifying, labelling and packaging substances and mixtures.

The company must therefore ensure consistency between:

classification → label → SDS

Depending on the applicable classification, the label may include:

• product identifier
• hazard pictograms
• signal word
• hazard statements
• precautionary statements
• supplementary information
• supplier details

What happens if the classification changes?

If a change in composition alters the mixture’s classification, its consequences for the label and SDS must be assessed at the same time.

This is one reason why it is not advisable to manage these two documents through completely separate processes.

A centralised system can use the same regulatory classification as the source for generating different hazard communication elements.

Can a European SDS be used in Türkiye?

A European SDS can be a starting point, but it should not automatically be used as a Turkish SDS.

This is particularly relevant because KKDIK is conceptually closely aligned with REACH, while the SEA Regulation is aligned with the European classification and labelling system.

These similarities can make the work easier, but they do not remove the need to check Turkish requirements.

What should a company check?

Before using a European SDS for a product marketed in Türkiye, the company should review at least:

• composition
• classification applicable in Türkiye
• SEA requirements
• specific SDS requirements
• regulatory information
• supplier information
• language
• professional requirements for SDS preparation
• information relating to KKDIK

Practical example

A company has an SDS compliant with REACH and CLP for a mixture marketed in Spain.

To market the same product in Türkiye, it may reuse much of the data:

• composition
• physical and chemical properties
• toxicological data
• ecotoxicological data
• transport information
• first-aid measures
• firefighting measures

However, a Türkiye-specific review must be carried out before generating the final version.

The benefit of a centralised database is that common technical data can be reused without maintaining entirely separate documents.

One data source, different regulatory outputs.

This reduces duplication while preserving the adaptations required for each market.

Recent regulatory changes

Türkiye’s chemicals and Safety Data Sheet framework has evolved in recent years. Companies marketing chemical products in Türkiye must monitor regulatory amendments as well as changes to deadlines and administrative procedures.

One of the most important areas is the evolution of KKDIK and its registration obligations. These obligations particularly affect manufacturers and importers marketing substances in Türkiye above the applicable thresholds.

Having a compliant SDS does not replace any registration obligations that may apply to a substance.

Developments in KKDIK registration obligations

Companies subject to KKDIK must check whether substances they manufacture or import fall within the scope of registration obligations.

This is particularly relevant for European companies already familiar with REACH, because a REACH registration does not automatically mean that a substance is registered in Türkiye.

A company may need to assess separately:

• REACH → obligations in the EU
• and
• KKDIK → obligations in Türkiye

The technical data used for both processes may largely overlap, but the legal obligations are independent.

Changes that affect SDS management

Regulatory changes may indirectly affect SDS even when they do not directly alter the document’s structure.

For example, a change in any of the following:

• a substance’s classification
• a restriction
• a substance included in a regulatory list
• toxicological information
• hazard information
• conditions of use

may mean that one or more SDS sections need to be reviewed.

Regulatory monitoring must therefore be connected to document management.

A company that simply stores SDS as separate files may not quickly identify which documents need to be reviewed after a change.

Common mistakes when preparing an SDS for Türkiye

1. Assuming KKDIK is exactly the same as REACH

Although KKDIK is strongly inspired by REACH, companies must apply Turkish regulations.

REACH compliance does not automatically mean KKDIK compliance.

2. Using a European SDS directly

An SDS compliant with REACH and CLP can provide a solid basis, but it must be reviewed before use in Türkiye.

The company must specifically check Turkish requirements.

3. Simply translating the SDS

Translating a European SDS into Turkish does not guarantee compliance.

The translation must be accompanied by a regulatory review.

4. Managing classification and SDS separately

A change in classification may simultaneously affect the label and several SDS sections.

Managing these elements in separate systems increases the risk of inconsistencies.

5. Failing to check professional requirements for SDS preparation

Türkiye has specific requirements relating to professionals authorised to prepare certain SDS.

A company outsourcing this work must check that the professional meets the applicable requirements.

6. Confusing substance registration with the SDS

KKDIK registration and the SDS are related but separate obligations.

Having an SDS does not mean that substance registration obligations have been met.

7. Failing to monitor composition changes

When a formulation changes, its impact on classification, labelling and the SDS must be assessed.

8. Keeping outdated versions

When a new SDS version is issued, the company must have a way to prevent outdated documents from continuing to be used or distributed.

SDS compliance checklist for Türkiye

Before marketing a substance or mixture in Türkiye, check the following:

This checklist is an initial control tool and does not replace a product-specific regulatory assessment.

How to keep SDS compliant in Türkiye

For a company with only a few products, keeping SDS up to date may seem relatively straightforward.

The situation changes when a portfolio contains hundreds or thousands of substances and mixtures.

A change to one substance may affect several formulations. A new classification may require numerous labels and SDS to be reviewed. A regulatory change may simultaneously affect products marketed in several countries.

Effective SDS management therefore requires more than storing documents.

Centralising substance data

The information used to generate SDS should be maintained in a centralised source.

This database may include:

• substance identity
• composition
• physical and chemical properties
• classification
• toxicological information
• ecotoxicological information
• restrictions
• transport information
• regulatory information
• translations
• supplier details

This allows a change to be applied to the affected products and documents.

Automating impact assessment

Suppose the classification of a substance used in 25 mixtures changes.

A manual process requires identifying each affected product and checking its SDS one by one.

A centralised system can link:

substance → formulations → classification → SDS → label

When substance information changes, the company can identify which products need to be reviewed.

This reduces the risk of an outdated SDS remaining in circulation.

Managing Türkiye alongside the European Union

For international companies, Türkiye is rarely the only market.

The same product may be marketed simultaneously in:

• Türkiye
• the European Union
• the United Kingdom
• the United States
• Australia
• New Zealand
• other markets

Technical information may be shared, but regulatory requirements are not necessarily the same.

The goal should therefore not be to maintain a single universal SDS.

The most effective approach is to:

centralise data → apply each jurisdiction’s rules → generate the relevant documentation.

This model avoids duplication while preserving the regulatory adaptations required in each market.

Frequently asked questions about SDS in Türkiye

Conclusion

Compliance with Safety Data Sheet requirements in Türkiye involves several elements of the Turkish regulatory system.

KKDIK provides the general framework for chemicals management, while the SEA Regulation sets the rules for classification, labelling and packaging. Specific SDS requirements must be assessed under the applicable Turkish framework, including Annex 2 to KKDIK.

Although the Turkish system is closely related to the European model, companies should not assume that an SDS compliant with REACH and CLP is automatically valid in Türkiye.

Classification, composition, labelling and the SDS must be managed as related elements. When relevant regulatory information changes, the company must assess which products and documents may be affected.

This challenge is even greater for organisations marketing large chemical product portfolios. A single change to a substance may affect many mixtures and their corresponding SDS.

Centralised management of substance and product data makes it easier to identify changes, control versions and generate documentation tailored to different jurisdictions.

How can ExESS help?

Managing Safety Data Sheets for Türkiye requires companies to control product composition, classification, regulatory information and market-specific requirements at the same time.

When a company markets the same products in Türkiye and other markets, maintaining separate documents for each jurisdiction can create duplication and increase the risk of inconsistencies.

ExESS centralises the information needed to generate and manage Safety Data Sheets and tailor documentation to the regulatory requirements of different markets.

With a centralised data source, companies can:

• manage substances and compositions in a single system
• apply market-specific regulatory rules
• generate SDS tailored to Türkiye
• manage different languages
• control versions and revisions
• identify products affected by changes to substances or classifications
• maintain consistency between SDS and classification
• reduce manual update processes

For companies marketing chemical products in Türkiye, the European Union and other international markets, this approach makes it possible to reuse shared technical data without assuming that regulatory requirements are the same in every jurisdiction.

Would you like to learn how ExESS can help you manage SDS and chemicals compliance in Türkiye and other markets? Request a demo.