• Relieve importers of their obligations to register and obtain continued market access in TURKEY (many Turkish importers will try to avoid registrations by purchasing REACH registered chemicals);

• Avoid dependence on a single importer and keep market access should one TURKEY importer cease trading;

• Gain advantages over other non-Turkish suppliers who do not appoint OR to register their substances;

Perhaps your existing TURKISH only representative(OR) has not communicated Ministry of Enviroment and Urbanisation information to you, has not recorded customers sold to and quantities imported, has not completed adequate supply chain communications, does not have the capability to complete a registration or charges you too much for their Only Representative (OR) service. If so, and if you are unsatisfied with your existing OR or you wish to transfer from your existing OR, it is possible to appoint MOLEKULER as your new OR.

Non-Turkish companies have a right to change only representative if they are unsatisfied. If the non-Turkish manufacturer nominates a new only representative the newly appointed only representative can benefit from the pre-registration done by the previous only representative if Ministry of Enviroment and Urbanisation is informed about the change. Normally the agreement shall be reached by previous OR, new OR and none-Turkish company that the previous OR agrees to terminate the Only Representative relationship and transfer all its liabilities and obligations under Ministry of Enviroment and Urbanisation to new OR. The power of attorney between new OR and none-Turkish company shall be reached for OR appointment, besides the OR transfer shall be done in Ministry of Enviroment and Urbanisation online system.

In accordance with the Article 9 of KKDIK, the OR takes on the obligations of importers under KKDIK Regulation, in which case importers will be regarded as downstream users (thus do not need to register). Those obligations include:

Maintain pre-registration data(company identity, annual tonnage, etc ) submitted to ministry through online registration;

Represent your company in Ministry of Enviroment and Urbanisation after pre-registration and keep you informed of the latest progress;

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 TURKISH importers and regulatory authorities and issue necessary documents to ensure KKDIK 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).

An Only Representative must be an TURKEY-based legal entity that has a sufficient background in the practical handling of substances and the information related to them required by the KKDIK regulation. 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 TURKISH KKDIK Regulation (pre-registration, registration, authorization, etc);

be capable of keeping an up-to-date list of Turkish importers within the same supply chain of the non-Turkish 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;