If Your KKDIK Application Is Rejected

Just when you thought the KKDİK registration process was complete and successful, you discover it was rejected by the ministry, turning your plans upside down. What can you do?

Running KKDİK registrations without any support can lead to confusion, lack of information, and disorganization, resulting in incomplete or incorrect applications. Similarly, receiving support from the wrong sources can lead to failure.

When you first submit your KKDİK registration dossier, the Ministry conducts a completeness check. If any deficiencies are found during this check, you are given a period to complete them, and access to your file is reopened during this time. At this point, a message appears in the Notifications section of the KKS stating, "Submitted Article Update Request - 'XXX application no' for the KKDİK Registration 'XXXX Registration Type' submitted by your application, an update request has been made by the Ministry. You can make the required changes from the Submitted Articles Module by 'XXX Final Date'." An automatic email is also sent to the contact person. If you fail to make the changes and complete the deficiencies, the registration of the article will be rejected and unfortunately, the registration fee will not be refunded.

If you make the changes and resubmit the file, the file will automatically re-enter Ministry evaluation at the end of the specified period. This review period may take up to three weeks, and if the Ministry finds that the necessary information has not been provided, your file will be rejected. In such a case, a notification and email will be sent to you via KKS, where you can also find details about the reasons for the rejection of the article.

According to the KKDİK Regulation, only an article or mixture that has been successfully registered and assigned a registration number can be manufactured or imported in quantities over one ton. Failing to complete a registration means you also fail to obtain the necessary permission from the Ministry. If you do not perform the necessary procedures within the registration and application period, you will not have obtained the required permissions for manufacturing or importing quantities over one ton. It is also possible that you complete the necessary procedures but your application is rejected and you are unable to meet the requested updates by the final registration date. Therefore, it is beneficial not to delay necessary actions and leave them to the last minute.

What can you do in such a case? If the application is rejected, the registrant can reduce the quantity of the substance to less than one ton per year or completely stop the manufacturing or importing of the substance. It is clear that your company would not want to face such a situation.

Registrants whose applications are rejected and who withdraw from leadership will need to purchase a LoA and undergo some processes again if a new leader is appointed. If a leader registrant withdraws from leadership, a new leader may emerge, but manufacturing and importing must not stop, and this must also happen before the final registration date. If the pre-MBDF's registration file is rejected before the final registration date, a new registration file must be submitted using the same pre-registration number, and a new registration fee must be paid based on the new payment reference number provided by the KKS system. However, if this rejection occurs after the final registration date or due to neglect by the relevant date, no articles submitted for registration will be allowed to be manufactured or imported in Turkey in quantities over one ton. In this case, a new registration file must be submitted, and the required fee must be paid. If the Ministry confirms the completeness of the registration or does not provide any adverse notification, the registrant can start manufacturing or importing after obtaining the registration number within 3 weeks from the presentation date.

The situations we explained above are valid for manufacturing and importing more than one ton of an article, either alone or in a mixture, or included in goods. The rejection of your KKDİK applications does not necessarily have to lead to a complete failure. As mentioned above, there are some ways you can follow; by conducting the process correctly and anew, you can be successful in your new application. However, at this point, there are some things you need to pay attention to. All processes need to be carried out by experts and on time. By delaying necessary actions, you shorten the time you have. A short period is also a limited and insufficient time for KKDİK experts and translators involved in the process. Trying to cram the procedures into this time frame can cause some critical points to be missed and your company to face failure. Ultimately, haste leads to waste.

You can benefit from our guidance by contacting us for your KKDIK registrations.