WHAT IS THE KKDIK ONLY REPRESENTATIVE and WHO CAN APPOINT AN ONLY REPRESENTATIVE?

Content addition date : 07-01-2025

What is the Only Representative?

According to the KKDIK Regulation No. 30105, there are two main actors responsible for compliance with the requirements of the regulation:

• Manufacturers of substances in Turkey,
• Importers of substances, either as a single substance or in a mixture.

In addition, companies based abroad can also carry out KKDIK compliance activities. However, they cannot do this directly; they must do so through a representative in Turkey. This representative is called the Only Representative within the framework of the KKDIK Regulation.

The Only Representative ensures compliance with the KKDIK for the foreign-based company’s importers in Turkey by carrying out the following activities under the KKDIK scope:

► Pre-registration
► Registration
► Managing authorization procedures
► Monitoring restriction conditions
► Preparing the registration dossier
► Preparing Chemical Safety Assessments
► Preparing a Chemical Safety Report, if necessary
► Preparing the Turkish Safety Data Sheet and label for the product

The KKDIK Only Representative signs a contract with the company they represent, clearly defining their duties, authority, and responsibilities. This contract must later be uploaded to the Chemical Registration System to ensure it is visible to the Ministry.

Who can Appoint an Only Representative?

In general, it concerns companies that are not established in Turkey but import chemical substances to Turkey. These companies are required to appoint an only representative located in Turkey to fulfil their legal obligations. Additionally, appointing an only representative facilitates communication with local regulatory authorities and ensures compliance with regulations in Turkey.

1.    Companies Established in Turkey but Managing KKDIK Compliance from Abroad

A company based outside of Turkey that exports chemicals to Turkey, even though it has an established facility in Turkey, can appoint an only representative and manage the KKDIK compliance process through its headquarters abroad.

For example; an EU based chemical manufacturing/export company with a production facility in Izmir, which wishes to export chemical substances to Turkey, must appoint an only representative to ensure compliance with Turkey's legal regulations and register its chemical substances according to the KKDIK Regulation. This only representative will manage the chemical substance registration, provide safety data sheets, and fulfil other legal obligations on behalf of the EU based company.

2.  Manufacturers With No Legal Entity In Turkey  

Manufacturers Not Legally Established in Turkey A company that is not established in Turkey and has no facility/office/branch in Turkey may want to sell chemical products in the Turkish market. In such cases, it is necessary to appoint a local only representative. This only representative will assume all legal responsibilities and communicate with the local authorities.

For example; a chemical manufacturer based in Japan, planning to export to Turkey and not wishing to open an office there, would appoint an only representative to fulfil Turkey's legal obligations.