The implementation to be done in accordance with the applicable Chemical Legislations in Turkey may be done by companies located within the borders of Turkey. Not based in Turkey companies may appoint Only Representative to fulfill the regulation obligation in condition the regarding regulation has Only Representative provision. In brief, not based in Turkey natural persons or legal entities (themselves, headquarters, branch or representatives), which are marketed their products to Turkey, appoints Only Representative based in Turkey to fulfill their relevant regulations obligations. CHEMLEG, as the regulatory compliance consultancy company, acts as an "Only Representative" for the regulations, enforced by Turkish authorities, such as KKDIK (Turkey REACH), Turkey Biocidal Product Regulation and Turkey CLP Regulation that have OR concept.
CHEMLEG OR Service for KKDIK (Turkey REACH) Regulation:
CHEMLEG OR Service For Turkey CLP Regulation:
CHEMLEG OR Service For Turkey Biocidal Product Regulation:
Acting as an Only Representative for KKDIK (Turkey REACH) Regulation: KKDIK Regulation No. 30105 brings responsibilities to the parties, mainly producers and importers, who deal with chemicals. According to Article 9 of KKDIK Regulation, non-based in Turkey companies, who export the substance in its own form, mixture or in article, may appoint an Only Representative (OR) in order to fulfill the importers obligations within the scope of KKDIK. Only Representative must have enough knowledge about the substance and the use of the substance. Importers' responsibilities within the scope of KKDIK are fulfilled by the OR in condition the exporter company appoints an OR for a substance which is imported in its own form, mixture or article. "Only Representative" bears responsibility for providing the necessary provisions for the presence of the relevant chemical substance in Turkey under KKDIK. In this case, the importer company is considered as “Downstream User” within the scope of KKDIK. The abroad company can appoint only one OR for the same substance. However, he can appoint different ORs for the different substances.
Acting as an Only Representative for Turkey CLP Regulation: Turkey CLP Regulation No.28848 states that the substances, which contribute the hazardous classification of the products, should be notified to the MoEU. It's called as SEA (C&L) notification. Also, any update of the substances’ classification and labelling information as well should be notified to the MoEU. According to Article 41(1) of Turkey CLP Regulation, SEA (C&L) notification can be done by the companies located in Turkey. According to Article 41(4) of Turkey CLP Regulation the companies, not located in Turkey, may appoint an OR, located in Turkey, by a mutual agreement to fulfill the obligation within the scope of relevant regulation. In this case, actions such as the notification requirement can be carried out through the Only Representative.
Acting as an Only Representative for Turkey Biocidal Product Regulation: Biocidal Products, which are marketed in Turkey, should be licensed within the scope of Turkey Biocidal Regulation No: 27449. The relevant implementations can be performed by a natural or legal entity who based in Turkey according to Article 11(1) of Turkey BPR. The manufacturer company, himself or the central or branch must based in Turkey to perform the licence implementation and other applications if they need. Companies that cannot provide this condition may appoint an Only Representative according to Article 6(2) within the scope of Turkey Biocidal Product Regulation. The manufacturer companies may perform the Turkey BPR provisions through the OR.
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