What is an Only Representative? How it works under KKDİK and REACH

The Only Representative is one of the most misunderstood mechanisms in chemical regulation. Some companies mistake it for a kind of agency, others for a needless cost. Used correctly, it both simplifies the supply chain and protects your commercial secrets — and for a manufacturer selling into Turkey it is often the only practical way to keep a substance on the market after the 30 September 2026 deadline.

1. What is an Only Representative?

Both KKDİK and REACH place the registration obligation on companies established within the country or region. A manufacturer abroad cannot register directly. That leaves two options:

• Option A: each importer registers separately for the quantity it imports.
• Option B: the manufacturer abroad appoints an Only Representative established in the target country; registration is done centrally, and the importers become downstream users.

The Only Representative is the natural or legal person, established in that country, who takes on the importers' obligations. The role is not commercial but one of regulatory compliance: preparing the registration dossier, tracking tonnage, keeping registrations current and maintaining the customer list.

2. Exporting to Turkey: KKDİK Article 9

Article 9 of the KKDİK Regulation allows a manufacturer, formulator or article producer established outside Turkey to appoint an Only Representative established in Türkiye to fulfil the importers' obligations. This is a right, not an obligation.

What happens when an Only Representative is appointed?

• The registration obligation passes to the Only Representative, who registers the substance in its own name.
• The Turkish importers move to downstream user status and no longer have to register.
• The manufacturer does not have to disclose formulation information to each importer separately — commercial confidentiality is preserved.
• Multiple registrations of the same substance are avoided; total cost falls.

What is required of an Only Representative

• be established in Türkiye,
• have sufficient background and practical experience in the safe handling of substances,
• keep importer information and supplied quantities up to date, and retain records,
• have access to Chemical Assessment Specialist (KDU) capacity able to prepare the registration dossier.

3. Exporting to the EU: REACH Article 8

The same structure works in the opposite direction. Turkish companies exporting substances, mixtures or articles to the EU cannot register directly under the EU REACH Regulation (1907/2006) — because they are established outside the EU. Article 8 of the Regulation lets a manufacturer outside the EU appoint an Only Representative established in the EU.

REACH's phased registration timeline (2010, 2013 and 2018) is complete. The rule today is clear: if 1 tonne or more per year is to be placed on the EU market, registration must be in place before it is placed. There is no longer a transitional "sell first, register later" period.

4. When does an Only Representative make sense, and when not?

When it makes sense

• You have more than one importer in the same country: separate registrations mean the same work done several times over, and more expensively.
• Your formulation is a trade secret and you do not want to disclose composition to your importers.
• Your customer portfolio is fluid; you do not want the registration to reset when an importer changes.
• You want to control the market yourself and manage compliance from a single point.

When it may not be needed

• You have a single, long-standing importer who bears the registration cost.
• The annual quantity is clearly below 1 tonne on a per-substance basis.
• Your product falls into an out-of-scope category (verify this by analysis rather than assuming it).

5. Three common mistakes in practice

1. Assuming "our distributor is our Only Representative". Commercial distribution and only representation are different things. An Only Representative is appointed in writing by the manufacturer and takes on the regulatory obligations.
2. Failing to track tonnage. The Only Representative is obliged to monitor the total quantity going to all importers. When the tonnage band is exceeded the registration must be updated; otherwise it lapses.
3. Double registration. Both the Only Representative and the importer registering the same substance creates unnecessary cost and data inconsistency.

6. Where to start

Whichever direction you are working in, the first step is the same: a substance-level inventory and tonnage assessment. Without that list you cannot decide whether an Only Representative is needed.

For the whole Turkish registration process: How to register under KKDİK · For the upcoming provisional registration date: 30 September 2026 · For your product documents: Is a safety data sheet mandatory in Turkey?

Frequently asked questions

This article is for general information; for your company's specific situation the official regulation text and Ministry announcements should be relied on. Last updated: 22 July 2026.