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17 Importers were Managed in a Single KKDIK Structure with a Only Representative
This text has been prepared as a representative case; Foreign manufacturer, importer and substance information has been anonymized.
Case summary
A chemical manufacturer established in Europe sold into Türkiye through 17 different importers. Separate KKDİK obligations for the importers increased registration costs, complicated tonnage tracking and introduced uncertainty into commercial relationships.
The foreign manufacturer appointed ONAY Mühendislik as Exclusive Representative within the scope of KKDIK in order to centrally manage the supply chain in the Turkish market. At the end of the project, which lasted five months, the registration procedures of the relevant substances were gathered under the Only Representative structure and the importers within the scope were defined as downstream users in KKS.
Initial status
The following was determined in the examination carried out at the beginning of the project:
- Sales to Turkey are made through different group companies and distributors.
- Importer lists are not kept up-to-date and in a central system
- The same substance was sent to Turkey under different trade names
- Product quantities and substance tonnages are not separated
- Some importers plan to register themselves
- It should be clarified which legal entity of the foreign manufacturer will appoint the Only Representative.
ONAY Mühendislik take?
In the first stage, the foreign manufacturer's legal entities, sales channels to Turkey and product portfolio were examined. It was determined which products were manufactured by which manufacturer and through which importers they were sent to Turkey. Then:
- Manufacturers and substances within the scope of Exclusive Representativeship identified
- Product-item-importer matching table has been created
- Export amounts for the last three years were calculated on an item basis
- Exclusive Representative appointment and representation documents were prepared
- Substance identity and composition information confirmed
- Necessary registration procedures were carried out as the Only Representative in KKS
- 17 covered importers were identified as downstream users
- KKDIK evidence documents showing the scope of supply were prepared for each importer
An annual update procedure was also established for adding importers, changing tonnage bands and expanding the product portfolio.
5-month project calendar
| Period | Work in progress |
|---|---|
| 1. moon | Legal entity, product and supply chain analysis |
| 2. moon | Substance identity and tonnage calculations |
| 3. moon | Exclusive Representative documents and KKS preparations |
| 4. moon | Registration procedures and importer definitions |
| 5. moon | Establishment of evidence files, quality control and annual tracking system |
Result
At the end of the project, the foreign manufacturer:
- Centralized KKDIK obligations in Turkey under the Only Representative structure
- identified 17 importers as downstream users within the scope of registration
- Reduced the risk of duplicate registrations for the same substance
- Provided proof of registration scope to its importers
- Established a system to track the quantities sent to Turkey on the basis of item and importer
- Started to directly manage commercial customer information and supply chain in the Turkish market
This case shows that the KKDIK Only Representative service is not just about preparing a registration file; shows that foreign producers, substances, tonnage and importers in Turkey must be managed together on a continuous basis.
ONAY Mühendislik offers KKDIK Only Representative, registration, downstream user identification, annual tonnage tracking and secure supply chain management services to manufacturers located outside Turkey.
Other project examples: ONAY Mühendislik case studies — lead registration, provisional registration, Only Representative and UFI–PCN projects.