What is a KKDIK Only Representative?
The Turkey’s EU REACH based KKDIK Regulation was published on June 23, 2017 and came into force on December 23rd, 2017. KKDIK regulation compliance requires all companies manufacturing or importing chemical substances on their own or in mixtures as well as in articles in Turkey to register these substances with the Ministry of Environment and Urbanization (MoEU). Only companies that have a legal presence within Turkey can submit KKDIK registrations to MoEU. Non-Turkey established companies must appoint a KKDIK Only Representative to submit KKDIK registrations.
A KKDIK only representative provides a legal entity in Turkey for suppliers to have their chemical substances subjected to either a KKDIK pre-registration or KKDIK registration process.
What does our KKDIK Only Representative Service offers?
We offer a comprehensive Only Representative Service for non-Turkey established companies in order to fulfill the pre-registration and registration obligations on their behalf wherefore non- Turkey established companies are not permitted to submit KKDIK pre-registration or registration process with their legal entity.
The service provides the necessary legal presence and representation in Turkey including representation in Ministry of Environment and Urbanization (MoEU), technical management of KKDIK pre-registration and registration, and submission of information to fulfill a company’s KKDIK obligations. This service includes the following;
- Legal Representation in Turkey: Legal representation at official authorities and in Substance Information Exchange Forum (SIEF) through the pre-registration and registration process.
- Documentation & Submission: Preperation and submission of the registration dossiers, chemical safety reports, safety data sheets and other technical documentation.
- Regulatory Information: Information on regulatory amandments on KKDIK and other regulations and questions and answers for all KKDIK-related questions.
Do I need a KKDIK Only Representative?
If the following apply to you, then you will need a KKDIK Only Representative to continue importing your goods into Turkey beyond 2023.
- Chemical substance manufacturer/supplier: You supply chemical substances on their own or in mixtures as well as in articles into Turkey as a non-Turkey established manufacturer/supplier…
- Chemical substance importer: You import chemical substances on their own or in mixtures as well as in articles into Turkey as an importer located in Turkey…
KKDIK Regulation [O.G. 30105 – 23.06.2017]
(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 Regulation. Only representative shall also comply with all obligations of importers under this Regulation.
(2) The only representative shall have a sufficient background in the practical handling of substances and the information related to them and, without prejudice to Article 32 (Obligation to Keep Information), 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 (Requirements for Safety Data Sheets).
(3) If an only 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.