KKDIK Only Representative

According to KKDIK Regulation, it is required to appoint a natural or legal person residing in Turkey as KKDIK Only Representative to fulfill the obligations of importer / manufacturer. The reason is that foreign companies cannot register or subscribe to the Chemical Registration System known as KKS alone. Therefore, they are supposed to collaborate with a Turkish entity. 

Article 9 mentions about who is Only Representative and its requirements.

ARTICLE 9 – (1)A natural or legal person established outside Turkey who manufactures a substance on its own, in mixtures or in articles, formulates a mixture or produces an article that is imported into the Turkey may by mutual agreement appoint a natural or legal person established in the Turkey to fulfil, as his only representative, the obligations on importers under the scope of this Bylaw. Only representative shall also comply with all obligations of importers under this Regulation.

(2) 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, 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 referred to in Article 27.

Only representatives have to be

•  A natural person or a legal entity with a physical presence in TURKEY.
• Have sufficient understanding of the practical handling of the substances and related information (CICR/KEK, CLP/SEA, SDS/GBF, TURKREACH/KKDIK, BPR, PPPR, TR Reg.)
• Appointed by mutual agreement with a manufacturer, formulator, or article producer from outside of Turkey
• Responsible for complying with the legal requirements for importers under TURKREACH (KKDIK)
• Only representatives are allowed to represent multiple non-TR suppliers, but they must keep information about each one separate.
• The non-TR company has to inform the importer(s) within the same supply chain of your appointment as an only representative. These importers are then regarded as downstream users for TURKREACH.

Our Only Representative Service

• Pre-Registration (Pre-SIEF) of foreign producers’ substances.
• Following the activities before the SIEF (Substance Information Exchange Forum) and informing the Overseas Manufacturer on any possible issue.
• Conducting all necessary communication with consortiums when established.
• The producer submits the 3-year amounts to the KKS System of the Ministry of Environment and Urbanization.
• Preparation of registration dossiers before the registration date, December 31, 2023.
• Determining the required test reports while preparing the Technical File.
• Monitoring the necessary activities while preparing the Technical File
• Preparation of Chemical Safety Reports.