Foreign manufacturers cannot register directly under KKDIK, so appointing a Turkey-based Only Representative (OR) is the most efficient route. Choosing the right OR determines the success of the process.
Key criteria: technical competence and IUCLID dossier capability; Lead Registrant and MBDF management experience; infrastructure to centrally manage tonnage and data sharing; respect for confidential composition data; transparent reporting; and sector references.
A weak representative creates delay and rejected-dossier risk. ONAY Mühendislik offers Only Representative services backed by Lead Registrant experience and digital MBDF infrastructure.
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Contact ONAY Mühendislik for KKDIK and REACH compliance support.
Yönetmeliğin resmî tam metni: KKDİK Yönetmeliği — Resmî Gazete.
What the role involves
An only representative registers on behalf of a manufacturer established outside Türkiye, keeps the list of covered importers, monitors annual volumes and answers to the authority during inspections. It is a continuing responsibility rather than a one-off filing service.
What to check before appointing
Ask how many substances the candidate currently manages, how tonnage is tracked, how importer changes are handled and what happens to your data if the relationship ends. Confidentiality terms matter too, since the representative sees your full formulation and customer list.
Why it usually costs less
With one representative the supply chain has a single registration. Left to importers, each of them registers separately, pays its own fee and often buys the same data access again. Above two or three importers the appointment is almost always the cheaper route.
Questions to ask before signing
How many substances does the candidate currently represent? How is tonnage tracked and reported back to you? What happens to the registration and the evidence file if the contract ends? Who signs the confidentiality agreement, and does it cover your customer list as well as your formulation?
Continuity matters more than price
Registration is a long relationship. A representative that changes staff frequently or cannot show how it monitors volumes will cost more in missed thresholds than it saves in fees.
Only Representative Contracts: Clauses That Matter
The Only Representative contract should name the substances covered, the reporting frequency for tonnage data, how the importer list is maintained, and what happens to dossiers if the appointment ends. Firms that change their Only Representative without a written handover clause discover that access rights and submission history do not transfer automatically, leaving a gap in registration status.