What is KKDİK (Turkish REACH) Only Representative?
KKDIK-Turk REACH Representation Services: Representation Services offered by Lisam includes KKDİK Only Representative, Authorized Representative, Third Party Representative, and Responsible Person.
KKDIK Turkish REACH requires all companies manufacturing or placing a substance on Turkish market in quantities greater than 1t/year to register that substance with the MoEU. For legal reasons, only companies with a legal entity in Turkey are allowed to submit a registration; however, non-TR companies may submit registration by appointing a TR-based KKDIK Only Representative to register on their behalf, in which case their importers will be regarded as downstream users and do not need to do registrations.
Lisam Systems is one of the largest Representation Service Provider and it provides cost-effective Representation Services to over 600 companies from over 27 countries and represents over 8000 substances. Non-Turkish manufacturers are not permitted to submit KKDİK (Turkish REACH) registration dossiers to the Ministry of Environment (MoE).
However, KKDİK (Turk-REACH) provides for a non-Turkish manufacturer to appoint a KKDİK Only Representative in order to fulfill the registration obligations on their behalf. Lisam Systems has longstanding experience acting as an OR for many companies around the world. The service provides the necessary legal presence and representation in Turkey including representation in MoE, technical management of KKDİK pre-registration and registration, and submission of information to the MoE to fulfill a company’s KKDİK obligations. Whether your company is entering Turkey market for the first time or your business is considering a change of OR, we can offer a comprehensive service tailored to your unique requirements.
A KKDİK-Turkish “Only Representative” is a legal entity established in Turkey, nominated by natural or legal persons that manufacture substances, formulate preparations or produce articles outside Turkey.
A KKDİK-Turk REACH “Only Representative” should have sufficient background in the practical handling of substances and the information related to them to be able to fulfil the obligations of importers. It should be noted that an “Only Representative” is not the same as a “Third Party Representative” referred to in KKDİK By Law.
A third party representative can be appointed by a manufacturer, importer or where relevant downstream user to allow this potential registrant to remain anonymous vis-à-vis other stakeholders in the data sharing process. A KKDİK Turkish REACH only representative is not obliged to disclose to the other participants in the data sharing process the identity of the “non-Community manufacturer” he is representing.
The Only representative (OR) will be appointed as per the legal entities as in the EU REACH. There are no differences in the OR process between KKDIK and REACH. A single Only Representative can be appointed by the multinational company for all legal entities operating in different countries. This can be done for both the purposes of pre-SIEF notification and registration.
However, the KKDIK Only Representative will need to consider submitting pre-registration notifications and registrations via his/her KKS account separately based on the volumes of substances of each ‘non- Turkish manufacturer’ that he represents.
Benefits of Appointing KKDIK Turkish REACH Only Representative (OR):
Relieve importers of their obligations to register and obtain continued market access in Turkey (many TR importers will try to avoid registrations by purchasing KKDIK registered chemicals);
Avoid dependence on a single importer and keep market access should one TR importer cease trading;
Gain advantages over other non-TR suppliers who do not appoint OR to register their substances;
Note: Importers will be exempt from KKDIK registration if their non-TR suppliers have registered; however, importers need to confirm with their suppliers' Only Representative that they are included in the inventory of importers and their tonnage and uses are covered by the OR. This can be done by asking for KKDIK Certificate of Compliance and Tonnage Coverage Certificate from the only representative of their suppliers before they put chemicals on the TR market.
Our main KKDIK-Turk REACH Only Representative services?
- On-call access to KKDİK Turkish REACH experts for support of KKDİK registration related questions,
- Participation in the SIEF, including contact and coordination with SIEF members,
- Data exchange and evaluation,
- Negotiation with SIEF and Consortium members,
- Authorized negotiations with Turkish Ministry of Environment,
- Notification to the MoE of quantities of products manufactured/imported and related risk assessments
- Submission of registration applications,
- Collection and submission of technical dossiers,
- Creation and submission of KKDİK compliant Safety Data Sheets (SDS),
- High-level discussions about risk assessments and use of information,
- Communication concerning substances to downstream users,
- Extended-SDS copilation services,
Are three or more of your answers yes in the checklist above?
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