Home/What are KKDIK exemptions?
What are KKDIK exemptions?
KKDIK exemptions ensure that some substances and uses are excluded from the registration obligation. However, exemption is never automatic. Each exemption is conditional and requires substance-specific justification. False exemption assumption is considered unregistered activity in the audit.
Which headings are exempt?
- Certain substances found in nature and not chemically modified
- Polymers meeting the conditions (obligation remains for monomers)
- Other regulated products: active pharmaceutical ingredients, food and feed additives
- Waste status materials
- Limited quantities for scientific research and development purposes
- Annual production and imports below 1 ton
How does the polymer exemption work?
The polymer itself may be exempt from registration. On the other hand, the monomers that make up the polymer are subject to registration at certain ratio and tonnage thresholds. So saying “my product is polymer” does not close the file. See our polymers KKDIK registration page for details.
Is staying below tonnage an exemption?
Quantities below 1 tonne per year do not require registration. However, this threshold is calculated per legal person and on the annual total. A company importing from more than one supplier may unknowingly exceed the threshold because it does not see the total. Therefore, we recommend that you compare the inventory with customs data.
Does the exemption remove classification?
No. Registration exemption does not relieve SEA classification, labeling and safety data sheet obligations. Even if a hazardous substance is exempt from registration, it must be labeled and reported to the supply chain with a safety data sheet. This distinction is the most confusing point in the field.
How to document an exemption claim?
Justification for exemption must be filed in writing. The file contains the identity of the substance, the provision on which the exemption is based and supporting evidence. This is the first question asked during the audit. In short, exemption is not an assumption, but a defensible document.
Related pages
Official full text of the regulation: KKDIK Regulation - Official Gazette.
For questions, contact ONAY Mühendislik.
How to use R&D exemption?
Uses for scientific research and development purposes are exempt for a limited amount and period. However, this exemption ends with the commercialization of the product. Companies that start pilot production and send samples to customers often do not notice this limit. For this reason, we recommend that you keep track of the amount and duration of the substances within the scope of R&D in a separate table.
Exemption or postponement?
Some companies think that temporary registration and calendar facilities are exemptions. However, these do not remove the obligation, they only extend it over time. To see the difference between temporary and full registration, see our temporary registration and full registration difference page. Also, follow the KKDIK registration calendar page for deadlines.