Individual Temporary Registration

What is KKDIK Individual Temporary Registration (ITR)?

Individual Temporary Registration (ITR) is an independent registration pathway under Türkiye's KKDIK (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation that allows manufacturers and importers to submit a temporary individual registration application in cases where the joint submission mechanism is unavailable or has ceased to function.

This mechanism is particularly applicable in the following situations:

• No Lead Registrant has been appointed or the joint registration dossier has not been submitted,
• A Letter of Access (LoA) is unavailable, access has been delayed, or it is not commercially viable,
• The Substance Information Exchange Forum (SIEF) is inactive or non-functional,
• The joint submission process cannot be completed within the applicable deadline for any reason.

Regulatory Basis for KKDIK ITR

Pursuant to the Ministry's announcement dated 6 March 2026, all substances manufactured or imported into Türkiye at ≥1 tonne/year must obtain one of the following by 30 September 2026:

• A Temporary Registration (Individual or Joint), or
• A Full Registration

After this deadline:

• Substances without a valid registration number cannot be legally manufactured or placed on the Turkish market.
• Compliance inspections will focus on the existence of a valid registration number in the KKS (Kimyasal Kayıt Sistemi).

Key Characteristics of KKDIK Individual Temporary Registration

• No LoA requirement: Registration can proceed independently of consortium data access.
• Data gaps permitted: Missing data can be justified in accordance with Annex-1 principles.
• Standalone submission: Not dependent on Lead Registrant activity.
• Deferred completeness: The dossier can be updated during the subsequent transition to full registration.
• Regulatory safeguard: Ensures business continuity in cases where the SIEF has ceased to function.
• Additional period: Missing information may be completed within a two-year additional period following the applicable registration deadline.

Strategic Considerations

ITR is not a replacement for full registration — it is a risk mitigation instrument.

Situations where KKDIK Individual Temporary Registration should be used:

• Where waiting for joint registration creates a non-compliance risk,
• Where the cost or time uncertainty associated with the LoA is unacceptable,
• Where the Lead Registrant is unreachable or unresponsive,
• Where the joint submission process cannot be completed within the applicable deadline.

Situations where KKDIK Individual Temporary Registration should not be used:

• Where a functioning joint submission exists with a viable Lead Registrant and reasonable LoA conditions.

KKDIK Individual Temporary Registration Deadline

The deadline for KKDIK Individual Temporary Registration (ITR) is 30 September 2026.

Companies manufacturing or importing substances subject to KKDIK must obtain a Temporary Registration or Full Registration number by this date in order to continue placing their substances on the Turkish market.

Applications submitted after the deadline may result in non-compliance and interruption of market access. For this reason, taking into account the Ministry's review timelines, it is recommended that ITR applications be completed no later than the end of August 2026.