KKDIK Only Representative in KKDIK – TURKREACH Regulation

The Ministry of Environment and Urbanization requests to appoint a natural or legal person residing in Turkey as kkdik only representative to fulfill the importer obligations under the regulations, because foreign companies cannot register or subscribe to the Chemical Registration System known as KKS alone.

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 Turkey may by mutual agreement appoint a natural or legal person established in 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.

The only representative should be provided by Chemical Safety Assessment Experts who are experts in KKDIK regulation and also within the scope of KKDIK Regulation Annex-18.

Only representatives have to be:

  • A natural person or legal entity established physically in TURKEY
  • Equipped with sufficient knowledge in the practical handling of the substances and information related to them (CICR/KEK, CLP/SEA, SDS/GBF,  TURKREACH/KKDIK, BPR, PPPR, related TR Reg.)
  • Appointed by a mutual agreement with a manufacturer, formulator or article producer, established outside Turkey
  • Responsible for complying with the legal requirements for importers under TURKREACH (KKDIK)
  • Only representatives can represent more than one non-TR supplier, but must keep the information related to each of them 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.

KKDIK Calendar Years

– 3/12/2017 – 31/12/2020: Pre-SIEF (Pre-registration) process.
– 01/01/2021 – 31/12/2023: It is the registration process. Pre-Registered substances can be manufactured, imported or placed on the market within the country in this process. Non-Pre-Registered substances can only be manufactured or imported or placed on the market within the country after the registration process is completed.
– 01/01/2024 and after: Substances not previously registered can only be manufactured or imported or placed on the market within the country after registration has been completed.

Turkish Chemical legislation is also known as Turkish REACH. The most important work of the foreign manufacturer within the scope of Turkish REACH is that it can make a good only representative selection. Election of the Only Representative is to be done before the registration period,January 01, 2021. The Only representative change is not available in the KKS system, but the companies that have pre-SIEF Pre-Registrations can do it again with the selected Only Representative. For pre-SIEF (pre-registration), it is important for companies to choose their Only Representatives as soon as possible. The reason is to lead the information transfer in the consortiums to be opened or to be a leader in joint registration processes. The Pre-Registration schedule started on 23/12/2017 and is still ongoing.

Our Only Representative Service

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