What does the Ministry's announcement regarding KKDİK on March 6, 2026, mean?
The Ministry’s text has several important implications.
First, the temporary registration approach has been raised regardless of tonnage. This means that companies can no longer rely solely on the attitude of “my final registration date is later, so I can wait.” For the purpose of inventory creation, it is expected that the relevant substance will be registered in the system.
Secondly, even if some information within the scope of the Procedures and Principles Annex-1 cannot be obtained, these deficiencies can still be documented in the KKS with justifications, allowing a temporary registration file to be submitted. This provides significant flexibility in practice, as it enables many companies to initiate the process without finalizing analytical data, usage information, or other technical content. It is also clearly stated that any missing information can be updated until the final registration dates.
Thirdly, the audit message for the period after September 30, 2026, is very strong. The Ministry states that necessary audits concerning the queries of temporary registration numbers for substances manufactured or imported by companies will be conducted after this date. Furthermore, it indicates that a temporary or full registration application must be made prior to the activities for new substances to be manufactured or imported after September 30, 2026. This should be interpreted as effectively closing the period for market entry without registration.
Fourthly, granting member companies the right to individual temporary registration with justification, even for a substance for which a complete registration file has been previously submitted by the leading company, shows that the Ministry has established a flexible but supervised model in practice. Disproportionateness in cost sharing, confidentiality concerns, or differences of opinion have been specifically mentioned.
Who is being affected?
This new approach is directly relevant for the following groups:
- Companies manufacturing substances in Turkey.
- Companies importing substances independently into Turkey.
- Companies importing or formulating mixtures; because registration assessment is conducted on a substance basis, not a mixture basis.
- Foreign manufacturers with multiple importers in Turkey.
- Foreign manufacturers that have established a registration strategy through a Only Representative.
- MBDF/SIEF participants awaiting a leading company or experiencing a blockage in the data sharing process.
A point that requires particular attention from mixture importers is clarifying who will cover each registered substance within the mixture in Turkey. Otherwise, everyone in the supply chain may assume that another party will handle the registration, leaving the substance effectively unaccounted for.
What application methods are available?
Full Registration
If the data package and registration strategy regarding the substance are sufficient, a direct full registration can be made. The Ministry has also clearly stated that companies that receive a full registration number do not need to obtain a temporary registration number.
Joint temporary registration / joint registration
If a leading company has been determined and the joint structure (MBDF) is operational, either a temporary registration or a full registration strategy can be implemented through the leader. In announcements regarding the sector after 2025, interim deadlines for the leading company and member firms have been approached with this rationale. With this announcement, the deadline for firms wishing to complete temporary registrations, either through the leader or joint temporary registrations, has also been unified to September 30, 2026. It is important to note that in MBDFs where a leader has not been appointed, joint temporary registrations cannot be made, so joint registrars have been directed towards individual temporary registration.
Individual temporary registration
If a leading firm has not been identified, a joint registration structure has not been established, discussions on data sharing have been inconclusive, or if it is not possible to proceed within a joint file due to reasons such as cost, privacy, and differences of opinion; individual temporary registration becomes a strong alternative.
The ministry’s announcement clearly states that the individual temporary registration was implemented specifically for this purpose, requiring companies that cannot make full registrations, joint registrations, or joint temporary registrations to complete their individual temporary registrations, independent of tonnage, by September 30, 2026.
