CAN THERE BE MULTIPLE REGISTRANT ROLES IN KKDIK REGISTRATION?

Content addition date : 29-05-2025

Example Scenario: Under the KKDİK Regulation, should a company that holds both the importer and Only Representative (OR) roles for the same substance in the same supply chain submit two separate registrations (one as an Only Representative and one as an importer)? In other words, if a company outside of Turkey appoints Firm A as its importer and also as its Only Representative, should Firm A submit two separate registrations?

According to the KKDİK Regulation, a company that takes on both the importer and Only Representative (OR) roles for the same substance must submit separate registrations for each role. That is, if Firm A is the importer of the substance for a company outside of Turkey and is also appointed as the Only Representative for the substance, Firm A must submit two separate registration applications.

•    Registration as Importer: If Firm A imports the substance into Turkey, it must register as the importer of the substance under the KKDİK Regulation. Importers are obligated to register chemicals that enter Turkey.

•    Registration as Only Representative: If Firm A is also appointed as the Only Representative, it must register on behalf of the foreign company (the original manufacturer). The Only Representative submits the registration application to the regulatory authority in Turkey on behalf of the foreign manufacturer and represents the substance.

The reason both roles require separate registration applications is that each role carries different obligations and responsibilities:

• As an importer, the company represents the substance entering Turkey and is responsible for fulfilling the obligations regarding the safe use of the imported substance.
• As an Only Representative, the company registers on behalf of the foreign manufacturer and ensures the manufacturer’s compliance with Turkish regulations. The Only Representative is responsible for fulfilling all obligations on behalf of the foreign manufacturer.

In conclusion, Firm A, which holds both the importer and Only Representative roles in Turkey, must submit two separate registration applications: one as an importer and another as an Only Representative. This is necessary because each role carries distinct responsibilities and obligations.