Recently, the Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) issued a significant announcement regarding the KKDIK chemical registration process, introducing major updates to the procedures, deadlines, and application requirements for individual interim registration.
What is Individual Interim Registration?
"Individual Interim Registration" is a new measure introduced by the Turkish Chemicals Consultation Group to streamline processes and accelerate the establishment of the national chemical inventory. In simple terms, when companies are unable to submit a complete registration dossier immediately (e.g., due to missing data, cost-sharing disputes, confidentiality concerns, or disagreements with the Lead Registrant), they may submit incomplete information with reasonable explanations to obtain an interim registration number in advance, ensuring trade compliance for their products.
Key Regulatory Changes: Unified Deadline, Pre-registration Numbers to Become Invalid
Critical Deadline: September 30, 2026
The announcement clearly states that all substances subject to KKDIK regulation, regardless of whether a Lead Registrant (LR) exists or the tonnage band, must complete registration to obtain a registration number (either interim or full registration) by September 30, 2026.
Important Reminders:
- After this date, substances without a valid registration number will not be allowed to enter the Turkish market.
- Pre-registration numbers will become invalid; only registration numbers will be valid.
- Companies that have already obtained full registration numbers do not need to apply for interim registration for the same substance.
Major Process Change: Joint Registrants No Longer Enjoy "Grace Period"
Past (Old Rules): After the Lead Registrant completed full registration, joint registrants could wait for their respective registration deadlines based on tonnage bands.
Now (New Rules): Regardless of the Lead Registrant's registration status, all companies must complete their own registration (interim or full) by September 30, 2026.
This means that companies previously relying on the Lead Registrant's progress must immediately initiate their own registration preparations to avoid delays that could result in pre-registration number expiration and loss of market access to Turkey.
Key Criteria: When Can Individual Interim Registration Be Applied For?
Companies may prioritize individual interim registration to achieve rapid compliance if any of the following situations occur:
- The Lead Registrant (LR) has not yet completed registration;
- The Letter of Access (LoA) agreement has not been shared by the Lead Registrant;
- No Lead Registrant has been designated for the substance;
- Even if LoA has been obtained, the company voluntarily chooses not to participate in joint submission.
How Should Companies Choose Their Registration Path?
Companies may select one of the following compliance paths based on their circumstances to ensure registration completion before the September 30, 2026 deadline:
1. Substances where LR has shared LoA pricing
- Joint submission – Full registration
- Individual interim registration (if choosing not to purchase LoA)
2. Substances where LR has not yet shared LoA
- May wait until April 15, 2026 to see if LR announces LoA pricing
- If not obtained by then, it is recommended to proceed directly with individual interim registration
3. Substances without a Lead Registrant
Recommended action: Proceed directly with individual interim registration
Q&A: 5 Core Questions, Authoritative Answers
Q1: Does the registration deadline of March 31, 2026 still apply to Lead Registrants (LR) for interim or full registration?
No. March 31, 2026 is no longer the interim registration deadline for LRs; the deadline for such substances is also September 30, 2026.
However, to ensure joint submission members can purchase LoA normally during this period, LoA-related fees must be determined no later than April 15, 2026, so that members intending to obtain LoA can complete their joint submission registration smoothly.
Q2: Before September 30, 2026, can joint submission members submit individual interim registration on their own regardless of the LR's registration status (whether a full dossier has been submitted)?
Yes, before September 30, 2026, companies may choose to submit using any of the following three methods:
- Joint submission – Full registration
- Joint submission – Interim registration
- Individual submission – Individual interim registration
Q3: Are the mandatory data requirements for individual interim registration still the information listed in Annex I?
Yes, the requirements remain unchanged. The data requirements in Annex I are the physicochemical data required for registration.
Q4: After September 30, 2026, will only full or interim registration numbers be checked, and will pre-registration numbers be considered invalid?
To continue placing chemicals on the Turkish market, all companies must obtain a valid registration number (either interim or full registration) by September 30, 2026. After this date, substances without a valid registration number may not be placed on the Turkish market; this requirement applies to all tonnage bands. Therefore:
- Only formal registration numbers (interim and full registration) have market access validity;
- Pre-registration numbers will become invalid and no longer hold compliance significance.
Q5: After September 30, 2026, will pre-registration no longer be accepted, with only interim or full registration required?
Currently, the competent authority has no clear rules regarding pre-registration after September; specific details await further official announcements.
CIRS Group Recommends Immediate Action
- Verify substance inventory: Confirm whether all substances you export to Turkey have completed or require (interim) registration.
- Confirm Lead Registrant status: Check whether the LR has submitted a dossier and whether LoA pricing has been shared.
- Choose registration path: Select joint submission (interim) registration or individual interim registration based on the guidelines above.
- Prepare documentation: Organize IUCLID dossiers, tonnage data, importer information, etc. as soon as possible.
- Contact us: If you have any questions regarding procedures, documentation preparation, or timelines, please feel free to contact us at any time.
CIRS Group is dedicated to assisting you!
