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KKDIK Downstream User and GTZ Evidence File

KKDIK • Türkiye • 2026

Sub-users may postpone KKDIK studies assuming that they are not direct importers. However, changes in use coverage, updated safety data sheet, supplier communication and cross-border supply should be closely monitored.

Technical content: ONAY Mühendislik regulatory team Experience: Since 2010

First determine the actual supply chain role

A company may act as a downstream user, importer or distributor for different transactions in the same product group. Role evaluation should be done on a product and supply flow basis, not company-wide.

The purchase record, delivery method, the party issuing the invoice and the customs movement of the goods are examined together. Written scope confirmation is obtained rather than relying solely on the supplier's verbal declaration.

  • Product list by supplier and country
  • Description of use and operating conditions
  • Current SDS and exposure information
  • Enrollment/scope confirmation correspondence

What should the GTZ evidence file show?

The secure supply chain file must show that the product used matches the actual process on site. When the terms of use change, the supplier should be contacted and the response received should be kept in a versioned format.

File; Purchasing, occupational health and safety, environment, production and quality teams should have a common data set. Thus, KKDIK control becomes a standard step in new product or supplier approval.

Checkpoints for continuity

New product, new supplier, change in import model and increase in usage should be defined as trigger events. When these events occur, the KKDIK role and registration scope are checked again.

ONAY Mühendislik establishes practical checklists and evidence folder structure linking downstream user and GTZ processes to purchase approval.

Frequently asked questions

Is the downstream user never considered an importer?

No. The role is determined based on the actual supply flow. The company that is a downstream user in some purchases may be an importer in another flow.

How should the supplier confirmation be stored?

The item/product, covered company, date, scope and responding party must be kept in writing and in version.

Definition of all KKDIK terms: KKDIK Glossary of Terms

This content was prepared by ONAY experts
Gözde Goetz
Deputy General Manager
Kocaeli Üniversitesi – Chemistry · KDU Certified · 13 years of experience
[email protected] · LinkedIn
Derya İnceli
Operations Manager
Gazi Üniversitesi – Chemistry · KDU Certified · 10 years of experience
[email protected]
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