On this page
- A KKDIK only representative for companies outside Turkey
- What a KKDIK only representative is
- Who needs a KKDIK only representative
- Only representative or importer registration
- What the regulation requires of an only representative
- Appointment documents
- Our duties as your only representative
- Switching only representative
- How an appointment runs with us
A KKDIK only representative for companies outside Turkey
A KKDIK only representative (OR) lets a non-Turkish manufacturer register its substances in Turkey once, for all of its Turkish customers, instead of leaving each importer to register separately. We act as your only representative from Turkey, hold the registrations under your appointment, and keep the records the regulation requires.
What a KKDIK only representative is
A KKDIK only representative is a natural or legal person established in Turkey, appointed by a non-Turkish manufacturer, formulator or article producer to fulfil the importer obligations under KKDIK. Once appointed, the only representative registers the substances, and the Turkish importers in that supply chain are treated as downstream users.
The role is set out in Article 9 of the KKDIK Regulation (Official Gazette of 23 June 2017, No. 30105). It is the Turkish equivalent of the only representative under Article 8 of EU REACH, with one difference that matters in practice: the representative must be established in Turkey. An EU only representative cannot hold a Turkish registration.
Who needs a KKDIK only representative
The question is not whether a foreign company is obliged to appoint one. It is not. The question is whether appointing one is better than leaving registration to your importers. An only representative usually makes sense in these situations.
- You sell the same substance to Turkey through several distributors or direct customers. Without an OR, each of them must register and buy its own letter of access.
- Your products are mixtures and you do not want to disclose the full composition to Turkish importers so they can register the components.
- You want to keep control of the Turkish market. If an importer holds the registration, switching distributor can leave the new one without a registration.
- Your customers are small importers who lack the technical staff to handle KKDIK.
- Your Turkish customers have asked you for a registration number or proof that registration is covered.
Only the non-Turkish manufacturer, formulator or article producer can appoint the only representative. A trader or distributor outside Turkey that does not manufacture cannot appoint one in its own right. In that case the manufacturer has to make the appointment, or the Turkish importer registers.
Only representative or importer registration
| Point of comparison | Only representative route | Importer registration route |
|---|---|---|
| Who holds the registration | The OR in Turkey, on behalf of the foreign manufacturer | Each Turkish importer, in its own name |
| Number of registrations per substance | One, covering all importers named in the supply chain | One per importer |
| Letters of access | Bought once, scaled to total volume through the OR | Bought by each importer, often in lower tonnage bands |
| Composition confidentiality | Shared only with the OR under a confidentiality agreement | Importers usually need full composition data |
| Changing distributors | No effect on the registration; new importer is added to the records | New importer must register before importing |
| Status of Turkish importers | Downstream users | Registrants |
| Tonnage band | Based on the total volume covered by the OR | Based on each importer's own volume |
The tonnage point needs care. An only representative registration covers the combined volume that reaches Turkey through it, which can push a substance into a higher band than any single importer would reach. That can mean an earlier deadline and more data. We model both routes during scoping, so you can see the trade-off before you sign.
What the regulation requires of an only representative
Article 9 is short, but it creates continuing duties, not a one-time filing.
- Importer obligations. The OR carries all registration duties that would otherwise sit with the importers: pre-registration, MBDF membership, joint submission, fees, dossier updates and responses to the Ministry.
- Knowledge of the substance. The OR must have sufficient knowledge of the substance and of its uses to answer for the registration.
- Up-to-date records. The OR must keep current information on the quantities imported and the customers sold to, and on the supply of the latest version of the safety data sheet referred to in Article 27.
- Record retention. Under Article 32, this information must be kept available for at least 10 years after the substance was last supplied, and produced to the Ministry on request.
- Tonnage band changes. If the covered volume moves into a higher band, the Ministry must be notified within 20 working days under Article 13(2), and the dossier upgraded.
The non-Turkish manufacturer also has a duty under Article 9(3). It must inform the importers in the same supply chain that an only representative has been appointed. From then on those importers are downstream users, with downstream user duties such as following the SDS and reporting new hazard information up the chain.
Appointment documents
The appointment is a contract between you and the only representative. The documents we prepare and collect at the start are:
- An only representative appointment agreement, naming the substances, the scope of the appointment, confidentiality terms, and the handover procedure if the appointment ends.
- A formal letter of appointment from the non-Turkish manufacturer, signed by an authorised signatory.
- Company documents for the manufacturer, such as a trade register extract, with an English or Turkish translation where needed.
- A list of Turkish importers to be covered, with legal names and tax numbers.
- The template notice to importers informing them of the appointment and of their status as downstream users.
- A confidentiality agreement covering compositions, volumes and customer data.
Whether notarisation or an apostille is needed for your company documents depends on how the Ministry and the forum treat the specific case. We confirm this at scoping so that documents are not legalised twice.
Our duties as your only representative
As your OR we run the registration side and keep the records in Turkey. In practical terms we:
- file or confirm pre-registration and join the MBDF for each substance;
- deal with the lead registrant and negotiate letters of access on your behalf;
- prepare and submit the member registration dossier in KKS, with the review statement by a certified Chemical Assessment Expert (KDU);
- keep the volume and customer register and reconcile it with your export data each year;
- track the latest SDS version supplied to each customer, and coordinate the Turkish SDS so it shows the registration number;
- answer Ministry questions and evaluation requests, and tell you in English what each one means;
- issue confirmation letters your importers can show to their customers or inspectors.
We do not take ownership of your data or of the letters of access bought for your registration. The appointment agreement states that these remain linked to you and transfer with you if you change representative.
Switching only representative
Companies change OR when service quality drops, when costs rise, or when they consolidate regulatory work with one consultant. The registration belongs to the supply chain you appointed for, so a change has to be planned.
- Review the existing agreement. We check notice periods, ownership of the letters of access and the handover clause.
- Sign the new appointment. The new agreement starts on a fixed date that matches the end of the old one, so there is no gap.
- Transfer in KKS and notify the Ministry. The registration and its records are moved to the new representative. We confirm the current procedure with the Ministry each time, because the Regulation itself does not set out the KKS steps for a change of representative.
- Inform the forum and importers. The lead registrant and the MBDF are told of the change, and importers receive a new notice.
- Collect the records. The previous OR hands over the volume, customer and SDS records it was required to keep.
If a previous representative is unresponsive, the change still needs evidence that the appointment ended. Keep copies of your termination notice and any correspondence.
How an appointment runs with us
- Scoping call and inventory, 1 to 2 weeks. We confirm which substances need registration, calculate tonnage through the OR route, and compare it with importer registration.
- Agreement and documents, 1 to 3 weeks. Contract, appointment letter, confidentiality agreement and company documents.
- KKS set-up and forum contact, 1 to 3 weeks. Pre-registration status, MBDF membership and first contact with the lead registrant.
- Registration. Letters of access, dossier and submission, as described on our KKDIK registration page.
- Ongoing service. Annual volume reconciliation, Ministry correspondence, dossier updates and importer confirmations.
For the current deadlines and what changed with the 30 September 2026 temporary registration step, see KKDIK registration deadlines.