The Role of KKDİK in Product Safety and Inspection Systems

The Role of KKDİK in Product Safety and Inspection Systems: An Assessment within the Framework of the 2026/12 Notification on Import Inspection of Consumer Products

Abstract
Product safety, in today's world where global trade volume and product diversity are rapidly increasing, has transcended being merely a policy area focused on consumer protection; it has become a multi-dimensional regulatory domain directly linked to public health, environmental protection, sustainable development and fair competition policies. In particular, chemical substances contained in imported consumer products can create long-term risks to human health and the environment, independent of the physical safety of these products.

In Turkey, the regulatory infrastructure created to manage these risks is built on two fundamental pillars: product safety legislation and chemical safety legislation. The 2026/12 Notification on Import Inspection of Consumer Products, which entered into force on 1 January 2026, addresses product safety at the import stage through a risk-based approach; while the Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals (KKDİK) emerges as the primary reference regulation determining the chemical risk dimension of this system.

The purpose of this article is to examine the 2026/12 Notification in detail from a product safety and import inspection perspective; and to evaluate KKDİK's direct and indirect role in this inspection system within an academic framework. The study addresses the normative links between the Notification's provisions and KKDİK, their interactions in practice, and the resulting consequences for importers, inspection authorities and market actors.

1. Introduction
Consumer product safety is recognized in modern legal systems as a fundamental area of public interest. The concept of product safety encompasses not only the physical characteristics of a product at the design and manufacturing stages, but all risks that the product may create to human health and the environment throughout its period of use. In this context, chemical substances occupy a central place in product safety discussions. The increasing complexity of global supply chains, with products manufactured, processed and presented to final markets in different countries, has made import inspections one of the most critical stages of product safety. Inspections conducted at the import stage aim not only at completing customs procedures, but also at identifying potential risks before products are placed on the market. The fundamental legal framework for product safety in Turkey is shaped through Law No. 7223 on Product Safety and Technical Regulations, related regulations and sector-specific notifications. In the field of chemical safety, the KKDİK Regulation, with its structure largely compatible with the EU REACH Regulation, plays a key role in ensuring the safety of both products placed on the domestic market and imported products. The 2026/12 Notification on Import Inspection of Consumer Products is positioned at the intersection of these two areas; restructuring product safety inspections with a chemical risk-based approach.

2. Structure and Purpose of the 2026/12 Notification on Import Inspection of Consumer Products
2.1. Objective and Scope
The fundamental objective of the 2026/12 Notification is to ensure compliance with applicable legislation of consumer products listed in Annex-1 at the import stage. The Notification performs a supplementary function to the General Product Safety Regulation and chemical legislation provisions with respect to product groups for which technical regulations are absent or whose provisions relating to human health and safety are limited. The Notification covers products imported under the Free Circulation Regime; returned goods and certain special cases are excluded from scope. This approach is consistent with the modern understanding of product safety, which aims to direct inspection capacity toward high-risk products.

2.2. Products Subject to Inspection and Chemical Risk Profile
When examining the product groups listed in the Notification's annex, office supplies, plastic and rubber-based articles, furniture components, textile accessories, laser products and various consumer equipment come to the fore. A large portion of these products are those with direct human contact during use or that may result in prolonged exposure. In particular, azo dyes, heavy metals (lead, cadmium, chromium VI), phthalates, polycyclic aromatic hydrocarbons (PAH) and dimethyl fumarate (DMF) are among the high-risk chemicals within both KKDİK and related restriction regulations.

3. TAREKS System and Risk-Based Inspection Approach
3.1. Function of TAREKS
Import inspections under the 2026/12 Notification are conducted through the Risk-Based Control System in Foreign Trade (TAREKS). TAREKS is an infrastructure that enables product safety inspections to be carried out in a digital environment, based on data and risk-focused manner. The system conducts risk analysis by taking into account numerous parameters such as importer company information, past inspection results, product origin, HS code, product type, brand and model information. As a result of this analysis, products can be directed to physical inspection or permitted for direct import.

3.2. Role of Chemical Data in Risk Analysis
Chemical substances contained in or likely to be contained in the product occupy an important place among the criteria used in risk analysis. Products containing restricted or licensed substances under KKDİK are assessed as having a higher risk profile and are directed to physical inspection. In this respect, TAREKS serves as a tool that indirectly integrates the chemical information infrastructure created within KKDİK into product safety inspections.

4. Normative Link between KKDİK Regulation and Product Safety
4.1. Basic Philosophy of KKDİK
The KKDİK Regulation is based on a preventive regulatory model aimed at preventing adverse effects of chemical substances on human health and the environment. The Regulation is based on the identification and control of risks related to chemical substances before they are placed on the market. This approach aligns with the fundamental objective of product safety legislation. For a consumer product to be considered safe, it is not only necessary to be free of physical risks; it also requires compliance of the chemicals it contains with applicable legislation.

4.2. Restrictions and Import Inspections
Restrictions introduced under KKDİK have direct consequences for imported consumer products. In many product groups listed in the Notification's annex, the presence of restricted substances or exceeding of limits can result in import refusal. This demonstrates that import inspections require not only product-based evaluation but also chemical content-based assessment.

5. Physical Inspections, Test Reports and KKDİK Application
5.1. Laboratory Tests and Technical Documentation
For products directed to physical inspection, importers are required to provide test reports prepared by accredited laboratories. These tests in most cases include analyses of substances restricted under KKDİK. The accuracy, traceability and compliance with legislation of test reports directly affect the outcome of the inspection. Misleading or falsified documents can result in severe administrative penalties.

5.2. Legal and Technical Responsibility of the Importer
The 2026/12 Notification clearly sets out the responsibility of the importer. Regardless of whether the product is inspected, the importer is responsible for the product's full compliance with all applicable legislation. In this context, detection of chemical content contrary to KKDİK; can result in administrative monetary penalties, market withdrawal, destruction and loss of commercial reputation.

6. Impact of Implementation on Market Actors
6.1. Importers and Manufacturers
The new Notification requires importers to manage product safety and chemical compliance processes in a more integrated and systematic manner. KKDİK registrations, safety data sheets and restriction analyses are now an integral part of product-based risk management.

6.2. Inspection Authorities
The risk-based approach enables more effective use of inspection resources; allowing focus on high-risk products. The integration of KKDİK data infrastructure into inspection processes establishes a more predictable and consistent inspection model.

6.3. Consumer Safety and Competition
Controlling chemical risks at the import stage is an important achievement in strengthening consumer safety. At the same time, it contributes to preventing unfair competition for compliant firms.

7. Conclusion and Assessment
The 2026/12 Notification on Import Inspection of Consumer Products can be evaluated as a strategic regulation that strengthens the chemical safety dimension of product safety inspections in Turkey. The Notification reflects modern product safety understanding through its risk-based approach and TAREKS infrastructure. Within this system, KKDİK transcends being merely legislation that provides for the registration and control of chemical substances; it becomes a decisive reference point in import inspections of consumer products. For importers, KKDİK compliance is now one of the fundamental elements of product safety and commercial sustainability. In conclusion, the strong interaction between the 2026/12 Notification and KKDİK demonstrates that product safety inspections in Turkey will evolve into a more comprehensive, data-driven and preventive structure in the future.

References
1. Law No. 7223 on Product Safety and Technical Regulations.
2. Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals (KKDİK).
3. Notification on Import Inspection of Consumer Products (Product Safety and Inspection: 2026/12).
4. General Product Safety Regulation.
5. European Union REACH Regulation (EC No 1907/2006).