Medicines & IMP

Cold Chain, Temperature Excursions and Release Decisions

Where the cold chain breaks, how excursion records are kept and what the release decision rests on. End-to-end management of temperature-sensitive products.

Authority
TİTCK / Ticaret Bakanlığı
Published
11 Aug 2026
Last reviewed
05 Sep 2026
Reading time
10 min
Quick answer

The cold chain is the preservation of the temperature range defined on the product's label at every step of transport and storage, and preservation is proven with a monitoring record. When an excursion occurs the process runs in three steps: the excursion is recorded and the product quarantined; the record shows the excursion's duration, its temperature and the stage at which it occurred; the decision is given with justification against the product's stability data and previously documented tolerances. The decision concludes in one of three ways: release, rejection or a hold pending further data. The deciding party is the sponsor's quality unit; a carrier or depot may recommend but cannot decide. The critical practical point is this: an intervention plan must run at the moment of excursion; recording and quarantine run simultaneously, not after the intervention completes. When the cold chain breaks, the real problem is not the lost product but the lost evidence; with evidence, the decision can mostly be made.

For a temperature-sensitive investigational product the journey is a single temperature undertaking stretching from the production line to the patient: every second must stay within the range defined on the product's label. Every moment this undertaking breaks is a temperature excursion, and the excursion raises a question about the product's quality: can this product still be used? The answer is not given by guesswork; it is given with stability data, with records and with a defined decision flow. Cold chain management is therefore a three-layer discipline: qualify the transport, record the excursion completely, and give the decision with its rationale. This article explains the chain from qualified shipper selection through depot receipt to excursion assessment and the release decision. Import routes, customs waiting times and site delivery receive specific attention; the rules apply to all temperature-sensitive research products.

Who is this for?

This guide is for every role working with temperature-sensitive research products. Clinical supply teams act by these rules when choosing the transport mode and carrier qualification. Depot operations must read the temperature record at receipt check and run the quarantine flow. Logistics providers are responsible for the qualified shipper and the maintenance of monitoring equipment. Quality units own the excursion assessment and the release decisions. Sponsor teams ensure that stability data is kept ready as the decision basis. Customs operations watch the product's conditions during waiting periods. Site staff take on the final temperature check at delivery and its record. In an audit the chain reduces to a single question: in which range did this product stay from manufacture to patient, and where is the proof. Each role must prepare the answer for its own segment.

Which products does it cover?

The scope is every research product carrying a temperature condition on its label. Biological formulations, vaccines and protein-based products requiring refrigerator conditions; cell and gene therapy materials shipped frozen; products defined at room temperature but with narrow limits; and comparators and samples requiring a temperature record. Each product has its own range, its permitted short-term tolerances and its stability basis; generalisation across products is not done. The range is defined by the label and must be consistent with the stability data in the file. At the edge of the scope sit other environmental factors such as light and humidity: for some products temperature alone is not managed but the whole set of environmental conditions. Sample and analysis materials also belong in the chain; their excursions are assessed as seriously as those of research products. However sensitive the product, the management principle is the same: the range defined, the monitoring recorded, the decision justified.

When does it apply?

Cold chain rules apply to every shipment of temperature-sensitive product, but certain moments concentrate the risk. On international import routes customs waiting times extend the product's stay inside the shipper and push toward the limit of its qualification. In transfers with connections responsibility changes hands, and each transfer should appear in the monitoring record as its own segment. Summer and winter conditions change the seasonal risk profile; pre-assessment is mandatory for shipments to extremely hot regions in particular. Unexpected congestion at depot receipt can lead to the product being shelved before the record is read. At site delivery the last mile carries risk: the receiving person must start the record and move the product into proper conditions immediately. Power cuts and equipment failure are the depot side's crisis scenarios, and the intervention plan must be written in advance. The excursion itself is not the exception; the exception is the excursion left unrecorded.

Legal framework and authority

The frame comes from good distribution practice and the product-quality provisions of the clinical trials legislation. The temperature and monitoring rules to be observed in the transport and storage of medicines are defined by the regulations on distribution practices; for research products these rules combine with the product quality and accountability provisions of the clinical trials legislation. The competent authority is TİTCK: it audits distribution practices, oversees the quality standards of research products and expects deviation management to be auditable. On the customs side, the product's conditions during waiting periods sit under the supervision of the customs administrations; the environment where temperature-sensitive goods are held at customs goes on record. The use of stability data as the decision basis is a general principle of the pharmaceutical quality system: a decision means the product is supported by recorded information. Guide documents are published and updated on the authority's official pages; this article summarises how the process works, and the current texts must govern.

Step-by-step process

  1. Extract the product's temperature profile from the file: label range, permitted tolerances and the stability basis.
  2. Select the transport mode: active refrigerated or passive insulated; justify with route, duration and seasonal conditions.
  3. Qualify the shipper: without pre-tests, temperature mapping and performance records in repeated use, no shipper enters a shipment.
  4. Set up the monitoring plan: recording devices verified, calibrated, with a defined reading procedure.
  5. Support the shipment with pre-notification: let the depot know the expected arrival and the product's temperature class in advance.
  6. Read the temperature record at receipt: no stocking before the record is viewed; the record is bound to the archive.
  7. On excursion, record immediately and quarantine the product; run the intervention plan simultaneously.
  8. Carry the assessment to the quality unit: request a decision reasoned with excursion duration, temperature limit and stability data.
  9. Bind the decision to record: release, rejection or further data; the decision enters the shipment file with date and signature.

Document checklist

  • The product's labelled temperature range and tolerance definition.
  • Stability data summary and the bases used in excursion assessment.
  • Shipper qualification reports and temperature mapping records.
  • Calibration documents: verification records of monitoring devices.
  • Shipment pre-notification and transport plan.
  • Receipt minute and the temperature record output.
  • Excursion record: duration, temperature, stage, intervention and dates.
  • Quarantine label and relocation record.
  • Assessment report and the release decision, signed.
  • Sponsor notifications and, where present, additional analysis results.

Parties and responsibilities

Party Responsibility
Sponsor Keeping stability data ready; defining the decision authority
Clinical supply unit Transport mode and route plan; shipper selection
Logistics provider Shipper qualification, monitoring devices and intervention
Depot operation Record reading at receipt, quarantine and condition keeping
Quality unit Excursion assessment and the release decision
Customs side Oversight of product conditions during waiting
Site team Final check at delivery and immediate move to proper conditions

The chain is as strong as its weakest link: a receipt without reading the record, a carrier that does not intervene, or a baseless decision alone drops the chain. When roles are written, an answer is produced instead of a question.

Exceptions and edge cases

The edges of temperature management need care. Short exceedances and persistent excursions are assessed separately; the product's defined tolerance can cover brief exceedances, and the decision rests on that data. There is the question of cumulative effect: the sum of brief excursions a product sees over its life can cross the limit even when each is individually acceptable; excursion records are therefore accumulated across the product's whole journey. In frozen products the thaw-refreeze cycle is a separate risk category and unacceptable for most products. The recording device itself can fail; if the device record is missing, the product record must be supported with accepted methods. For shipments that will wait long at customs, the shipper's duration must be planned; where necessary, proper storage within or near customs is arranged in advance. At site delivery, who receives and how the record starts must be defined. On either side of the edge the principle is constant: the decision comes from the triple of record, basis and rationale.

Common mistakes

The most common mistake is stocking the product at receipt without reading the temperature record; the excursion stays silent and surfaces on the way to the patient. The second is using an unqualified shipper; even if the record looks good when the product is opened, the shipper carries no assurance. The third is using monitoring devices without calibration; the record is legally baseless. The fourth is releasing the excursion without a decision; the depot cannot open the product to use on its own. The fifth is giving the decision without stability data; a baseless release falls at audit. The sixth is not tracking cumulative excursion; accumulating brief exceedances go unseen. The seventh is leaving site delivery responsibility undefined; the record never starts in the last mile.

Important notice

This article is general information, not legal or customs advice; for the transport of temperature-sensitive products and release decisions, the applicable distribution practice legislation and authority guides must govern. Product examples and temperature ranges in the text are for orientation and are not binding. Decision processes are the subject of the pharmaceutical quality system; this article does not replace quality decisions.

Frequently asked questions

Is a product automatically rejected on a temperature excursion?

No. The excursion is the trigger required for a decision, and the decision concludes with three options: release, rejection or a hold pending further data. The decision's basis is the product's stability data and defined tolerances; the excursion's duration, the temperature reached and the stage where it occurred are assessed together. Automatic rejection arises only where conditions exit the product's definition, for instance in a frozen product where thawing is not acceptable. The quality unit gives the decision and its rationale goes on record; an unrecorded or baseless decision can lead to the invalidation of the product's entire use at audit.

Who gives the release decision?

The sponsor's quality unit. The depot, carrier or site recommends the decision; without the decision authority's approval the product is not opened to use. The decision authority must be tied to a single address in the responsibility matrix, and that address must never stand empty. The decision is given in writing and with rationale: on which data it rested, the excursion's nature and the decision's scope all appear in the decision record. The question asked at audit is not only the outcome but the process: by whom, on what basis and when the decision was given.

How is the cold chain preserved at customs?

By planning. On the import route, waiting times are estimated in advance and the shipper's duration calculated with that waiting included. Where necessary, proper storage at or near customs is arranged beforehand; if the product must leave the shipper, that transition also enters the record. Customs administrations should be informed of the goods' nature, and priority handling requested for temperature-sensitive shipments. During the wait the temperature record continues without interruption; a gap in the record is assessed as seriously as an excursion. Every minute spent at customs must be a planned part of the chain.

Can a decision be made without stability data?

It should not be. The decision's basis is the product's recorded stability information and defined tolerances; without that basis the decision is a guess, and a guess is not accepted in a patient-safety context. Where the basis is missing, the path is open: the product is held in quarantine, further data is requested from the manufacturer or sponsor and, where required, an analysis sample is taken. Until the further data arrives the product is not used. In some cases the sponsor can support the decision with a risk analysis resting on the product specification; but that analysis too must be written and signed. A hasty baseless decision is the chain's most expensive error.

Official sources

  1. TİTCK Clinical ResearchTİTCK / Ticaret Bakanlığı · verified 07 Sep 2026
  2. Official Gazette Index (31 December 2025)TİTCK / Ticaret Bakanlığı · verified 07 Sep 2026
  3. Product Safety and Inspection Communiqué AnnouncementsTİTCK / Ticaret Bakanlığı · verified 07 Sep 2026
Important: This operational overview is not legal or customs advice. Product classification, GTİP, origin and intended use can change the applicable procedure. Verify the current text with the authority before shipment.

Revision history

v1.1 · 07 Sep 2026 — Content import: external full text applied.

v1.0 · 11 Aug 2026 — Initial source-backed publication.