Only Representative (OR) under Turkey’s KKDIK: End-to-End Guide (Including TPR)

In Turkey, chemical compliance under KKDIK depends on who is considered the importer and who carries registration obligations. For non‑Turkey manufacturers, the answer is usually the Only Representative (OR) model.

In this guide you’ll learn:

• what an OR is under KKDIK,
• who can appoint one (and who cannot),
• how importer obligations shift,
• practical KKS workflows,
• and how Third Party Representation (TPR) differs.

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1) What is an Only Representative under KKDIK?

An Only Representative is a Turkey‑based natural/legal person appointed by a non‑Turkey manufacturer/formulator/article producer to carry importer obligations under KKDIK.

Key outcome:

• Importers covered by the OR are intended to move to a downstream user role.
• Registration and compliance can be managed centrally even with multiple importers.

Compliance note: An OR is not “just a file uploader.” The OR manages tonnage, scope, importer list, data chain, and audit‑ready records.

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2) Who can appoint an OR?

Three main groups can appoint an OR:

1. Substance manufacturers (as‑is, in mixtures, or in articles imported to Turkey)
2. Formulators
3. Article producers (when obligations apply)

Who cannot? (most common mistake)

• Distributors generally cannot appoint an OR.
  If roles are mis‑assigned, the model becomes non‑compliant by design.

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3) What changes for importers once an OR is appointed?

The OR model prevents each importer from having separate registration obligations.

What changes:

• Registration strategy and dossier management are led by the OR.
• Covered importers shift the core registration duty to the OR umbrella.

What does not change:

• Safe use compliance (SDS/GBF alignment),
• supply‑chain communication,
• internal risk management.

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4) OR responsibilities (practical checklist)

Think of OR duties in five blocks:

4.1 Scope and portfolio management

• Which substances are in OR scope?
• Which mixture components are critical?
• Which articles trigger obligations?

4.2 Tonnage and importer list control

• Tonnage is tracked per substance for Turkey supply, not just totals.
• Importer list must be accurate and up to date.
• In KKS files, importer data and supplier relationships should align with the data‑sharing strategy.

4.3 Data chain and dossier discipline

• Substance identity, use map, classification/labeling, hazard data, revision control
• Audit‑ready evidence: decision notes, versioning, document trails

4.4 Joint registration & data sharing

KKDIK registration is built on joint registration and data sharing:

• Contact with data owners
• LoA/licensing management
• Cost sharing and fair compensation
• Technical alignment on substance boundaries

4.5 Continuous compliance (change management)

• Tonnage increases
• New importer additions
• New uses
• Classification changes → SDS updates
• Site/raw material changes
  All must be managed on a defined timeline.

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5) OR appointment process (8‑step workflow)

1. Role confirmation: Manufacturer? Formulator? Article producer?
2. Substance inventory: CAS/EC, purity, UVCB logic, mixture components
3. Turkey tonnage & customer map: importer list + annual tonnage
4. Use map: customer use conditions and sectors
5. Gap analysis: data/identity/classification/SDS/evidence gaps
6. OR contract: scope, confidentiality, change‑notification, responsibility matrix
7. KKS workflow: account/dossier discipline + trackers + checklists
8. Joint registration/data‑sharing plan: cost, timeline, access, negotiation strategy

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6) TPR vs OR: what is different?

TPR (Third Party Representative) is not the same as an OR.

TPR purpose:

• Protect company identity in data‑sharing/joint registration,
• run negotiations through a proxy,
• represent multiple parties when needed.

Critical difference:

• OR is appointed to manage importer obligations for a non‑Turkey manufacturer.
• TPR represents the company in data‑sharing talks; legal responsibility stays with the registrant.

When to use TPR?

• Sensitive negotiations with competitors,
• confidentiality needs,
• limited internal resources for technical talks.

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7) Common mistakes (and quick fixes)

1. “We’re a distributor; we appointed an OR.” → Wrong role.
   Fix: role verification + contract scope correction.

2. Importer list not updated → tonnage/scope drift.
   Fix: monthly/quarterly importer‑tonnage reconciliation.

3. Uses not covered → customer use becomes out‑of‑scope.
   Fix: update use map + registration strategy together.

4. Data‑sharing negotiation is unplanned → time/cost blow‑ups.
   Fix: negotiation playbook + budget/timeline.

5. TPR confused with OR → wrong process design.
   Fix: separate “TPR = confidentiality/negotiation” vs “OR = importer obligations.”

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8) Pier Compliance approach (OR = process management)

We treat OR services as market access + evidence chain + ongoing compliance, not just file submission.

Pier Compliance OR service scope

• Scope analysis: substance/mixture/article + Turkey tonnage/use map
• OR contract package and responsibility matrix
• KKS workflow setup (audit‑ready discipline)
• Joint registration & data‑sharing strategy (cost + timeline)
• TPR option for confidentiality and negotiation
• Continuous compliance: change management + checklists + status reporting

Deliverables

• OR compliance roadmap
• Substance portfolio file (CAS/EC/tonnage/uses)
• Importer/downstream user management pack
• Data‑sharing negotiation kit (playbook + templates)
• Audit‑ready evidence package

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Mini FAQ

Does an OR remove all importer obligations?
No. Registration is centralized, but safe use and supply‑chain duties remain.

Can OR and TPR be used together?
Yes. OR manages importer obligations; TPR supports confidential data‑sharing negotiations.

Most critical success factor?
Live importer list + tonnage + use map, supported by audit‑ready evidence.

Fast start: top 3 data points?
Substance list (CAS/EC), Turkey annual tonnage, uses/customer sectors.

How do we work with Pier Compliance?
Scope & risk screening first, then roadmap and KKS/data‑sharing plan.

CTA: Build your OR/TPR strategy with Pier Compliance → /contact