TURKREACH KKDIK ONLY REPRESENTATIVE
TURKREACH KKDIK Only Representative
TURKREACH requires all companies manufacturing or placing a substance on Turkish market in quantities greater than 1t/year to register that substance with the Ministry of Enironment and Urbanisation (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 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.
Our TURKREACH only representative service costs per substance per year are changes depending on the number of substances. If you are looking for a cost-effective "Only Representative" or wish to change only representative, please don't hesitate to contact us for further advice.
Benefits of Appointing TURKREACH Only Representative (OR)
Relieve importers of their obligations to register and obtain continued market access in the TR (many TR importers will try to avoid registrations by purchasing TURKREACH 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 TURKREACH 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 TURKREACH Certificate of Compliance from the only representative of their suppliers before they put chemicals on the TR market.
ARTICLE 9 – (1) A natural or legal person established outside Turkey who manufactures a substance on its own, in mixtures or in articles, formulates a mixture or produces an article that is imported into the Turkey may by mutual agreement appoint a natural or legal person established in the Turkey to fulfill, as his only representative, the obligations on importers under this Title.
(2) The representative shall also comply with all other obligations of importers under this Regulation. To this end, he shall have a sufficient background in the practical handling of substances and the information related to them and, without prejudice to Article 32, shall keep available and up-to-date information on quantities imported and customers sold to, as well as information on the supply of the latest update of the safety data sheet referred to in Article 27.
(3) If a representative is appointed in accordance with paragraphs 1 and 2, the non-resident manufacturer in Turkey shall inform the importer(s) within the same supply chain of the appointment. These importers shall be regarded as downstream users for the purposes of this Bylaw.
Who Can Be Appointed as TURKREACH Only Representative?
An Only Representative must be a TR-based legal entity that has a sufficient background in the practical handling of substances and the information related to them required by the TURKREACH regulation Article 9(2).
To be more specific, an only representative shall:
have the ability/expertise to understand and implement the responsibilities of an importer that only representatives take on under the provisions of TURKREACH (CLP-registration, Pre-SIEF management, CRS management, registration, authorization, etc);
be capable of keeping an up-to-date list of TR importers within the same supply chain of the non-TR manufacturer it represents;
have a record-keeping system with data on imported quantities and all uses covered;
be capable of keeping the latest information on the supply of safety data sheets;
Click here to know more about your obligations under TURKREACH .
What does TURKREACH Only Representative do?
In accordance with the Article 9 of TURKREACH , the OR takes on the obligations of importers under TURKREACH , in which case importers will be regarded as downstream users (thus do not need to register).
Those obligations include:
Maintain registration data (company identity, annual tonnage, etc ) submitted to MoEU through CRS (KKS) Online System
Represent your company in SIEF/Consortium after pre-SIEF registration and keep you informed of the latest progress of SIEF/Consortium;
Supply Safety Data Sheets or transmit SDS along the supply chain and keep information on the supply of the latest update of the SDS;
Communicate with TR importers and regulatory authorities and issue necessary documents to ensure TURKREACH compliance;
Keep an up-to-date list on the inventory of importers and the tonnage covered for each of these importers and keep the above information for at least 10 years and provide it to enforcement authorities upon request;
Registration, notification and authorization of substances(additional contract needed);
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