Why Should You Appoint an Only Representative (OR) in Turkey?

Many exporters with EU REACH registrations leave KKDIK scope to importers despite not having a local company in Turkey. This approach can lead to role ambiguity, registration visibility, and continuity issues.

Root cause (regulatory framework). In Turkey, KKDIK requires obligations to be managed through KKS (Ministry system) with the correct role. For exporters without local legal entity, OR (Only Representative) appointment ensures that registrations/notifications are made under direct exporter control.

When is OR required?

If you do not have a local company in Turkey and are directly placing products/substances on the market,

If you want to maintain flexibility to change your importers,

If you want SDS/labeling and tonnage evidence managed in one place.

Solution (clear path).

Prepare substance inventory (CAS/EC, annual tonnage, use).

Execute OR contract (role, confidentiality, data sharing, fees).

Complete notification/pre-registration related to KKS access.

Align Turkish SDS/labeling and technical files according to local regulations.

Share timeline with internal stakeholders/importers.

Common mistakes.

Losing registration and visibility by saying "the importer handles it"

Delaying SDS TR and labeling compliance

Delaying tonnage evidence (invoices/logistics documents)

FAQ (short).

What happens if the importer changes while OR exists? → Continuity is maintained as registrations remain under OR.

Does the importer see CAS RN? → Depends on KKS role settings; generally visibility and permissions are determined on a role basis.

Share your CAS/EC + tonnage list with info@piercompliance.com; we'll send the most cost-effective OR roadmap within 24 hours.