Product Tracking System (ÜTS) Notification and Cosmetic Regulatory Compliance Processes

Ürün Takip Sistemi (ÜTS) Bildirimi — Product Tracking System Registration

The Product Tracking System (ÜTS) is an infrastructure developed in cooperation with TÜBİTAK and the Turkish Medicines and Medical Devices Agency (TİTCK), enabling cosmetic products manufactured domestically or imported into Turkey to be tracked from the production line to the point of sale and end-use.

Purpose of the ÜTS System

  • Registering cosmetic products in a central system
  • Ensuring product traceability throughout the supply chain
  • Protecting public health and consumer safety
  • Supporting effective and transparent market inspections
  • Enabling rapid response to product-related safety risks
  • Facilitating the withdrawal of unsafe or non-compliant products from the market

In line with the announcement made in March 2016, cosmetic manufacturers were required to transfer their notifications from the former EBS platform to ÜTS within 18 months and to submit all new notifications exclusively through ÜTS.

Company records previously registered in the EBS system were automatically transferred to ÜTS. However, companies must obtain an e-signature and define a Responsible Technical Personnel in order to actively use the platform.

For each cosmetic product, notifications are submitted to ÜTS by uploading product name, formulation details, content information and product images.

Cosmetic Company Registration

Companies engaging in cosmetic manufacturing or import activities for the first time must complete a cosmetic company registration as a manufacturer and/or importer. Company registration is performed through both the ÜTS platform and the Electronic Application System using MERSİS or VEDOP-based company data. Contact details and authorized signatory information must be consistent across both systems.

In addition to company registration, changes such as tax number, trade name, address, authorized signatory appointment or status updates may also be processed with professional support from our expert team.

Our consultancy team provides end-to-end assistance throughout all stages of the cosmetic company registration and ÜTS compliance process.

Responsible Technical Personnel (Mesul Müdür)

Under Turkish cosmetic regulations, manufacturers and distributors are required to appoint a Responsible Technical Personnel who is accountable for notifications, documentation and product compliance. This position is also referred to as “Cosmetic Responsible Manager”.

According to Law No. 5324, the manufacturer is defined as the real or legal person who produces, imports, places the product on the market or identifies itself as the manufacturer by placing its trademark or trade name on the product. One of the fundamental obligations of the manufacturer is to employ a qualified Responsible Technical Personnel.

The Responsible Technical Personnel is required to follow developments in national legislation, good manufacturing practices and regulatory updates, ensuring the professional competence and legal compliance of the company.

Through our experienced regulatory team, we closely monitor domestic and international legislation and provide continuous updates and guidance to the companies we support.

Who Must Employ a Responsible Technical Personnel?

According to the Cosmetics Regulation, producers, distributors, promotional organizations and media agencies involved in product supply are considered within the scope of “manufacturer” responsibility. Therefore, companies placing cosmetic products on the market must employ a Responsible Technical Personnel with adequate professional competence.

Who Can Serve as Responsible Technical Personnel?

In accordance with the regulation, pharmacists — or chemists, biochemists, chemical engineers, biologists or microbiologists with at least two years of proven experience in the cosmetics field — may be assigned as Responsible Technical Personnel. They are responsible for verifying compliance of products with cosmetic legislation, GMP requirements and all relevant regulations.

Companies that fail to employ a Responsible Technical Personnel may be subject to administrative fines under Law No. 5324.

Cosmetic Product Registration in ÜTS

According to the Cosmetics Law No. 5324, cosmetic products must be notified to the Ministry via the ÜTS platform before being placed on the market. Any changes made after initial notification — such as formulation, packaging or manufacturer updates — must also be reported.

Producing, packaging, importing or expanding business activities without ÜTS notification is prohibited and may result in legal penalties.

Following product notification, the Ministry does not issue a written approval document. All legal responsibility for the product remains with the manufacturer as defined under relevant legislation.

For this reason, both formulation and packaging (primary container and outer box) must fully comply with cosmetic legislation and labelling requirements.

Export Certificate (Free Sale Certificate)

Through the ÜTS system, export certificate (Free Sale Certificate) applications may also be submitted electronically for cosmetic products manufactured in Turkey or produced on behalf of international brands under authorized agreements.

Once the institutional payment is completed, approved certificates are issued by TİTCK and delivered to the registered company address.

Luzpos Trading provides full-scope consultancy and operational support throughout the ÜTS notification, regulatory compliance and export certification processes with its experienced and legislation-focused professional team.