KKDIK Regulation Only Representative Service

Only Representative refers to an established or legal entity resident in Turkey who is appointed by a manufacturer, formulator or article producer resident outside of Turkey to fulfil the importer's obligations.

Within the scope of KKDIK Regulation No. 30105, the registration of substances imported into Turkey on their own, in mixtures or in some cases in articles should be submitted by importers established in Turkey. In other words, each importer who imports the substance should register the substance they import. However, the established or legal entity established outside Turkey who manufactures the substance, formulates the mixture or produces the article should appoint an only representative to carry out the necessary registration process for the substances imported into Turkey (on their own, in mixtures or in articles). In this case, importers established in Turkey will be considered as downstream users of the only representative and therefore will not have registration obligations.

In case of appointment of an only representative, the only representative is responsible for fulfilling the importer obligations within the scope of KKDİK Regulation No. 30105.

The representative shall have a sufficient background in the practical handling of substances and the information related to them and, without prejudice to Article 32 of the KKDİK Regulation, shall keep available and up-to-date information on quantities imported and customers sold to, as well as information on the supply of the latest update of the safety data sheet (SDS-GBF) referred to in Article 27 of the KKDİK Regulation.

If a representative is appointed in accordance with paragraphs 1 and 2, the non-resident manufacturer in Turkey shall inform the importer(s) within the same supply chain of the appointment. These importers shall be regarded as downstream users for the purposes of this Bylaw.

Who can Appoint an Only Representative within the Scope of the KKDIK Regulation?

According to Article 9(1) of the KKDİK Regulation, an established or legal entity established outside Turkey who manufactures a substance, prepares a mixture or produces an article to be imported into Turkey, on its own, in a mixture or in articles, may appoint an established or legal entity established in Turkey as their sole representative to fulfil the importer obligations under this Regulation. Distributors cannot appoint an only representative as they are not specified in Article 9(1).

An importer who imports a substance, mixture or article from a company outside Turkey that has appointed an “Only Representative” will be considered a downstream user and therefore does not need to register.

Our Only Representative Services within the Scope of KKDIK Regulation:

•    Pre-registration/registration procedures of the substance

•    Fulfilment of importer obligations

•    Communication with other pre-SIEF (Substance Information Exchange Forum) members and taking necessary actions

•    Providing necessary information in the supply chain

•    Providing communication with importers established in Turkey

•    Contacting consortia and/or data owners to obtain the necessary information for substance registration and taking necessary actions

You can contact our expert team to get more information on the subject.