What is a Responsible Technical Person?
A Responsible Technical Person is an individual responsible for ensuring that cosmetic products placed on the Turkish market comply with Good Manufacturing Practices (GMP) and all relevant cosmetic legislation.
In Türkiye, companies involved in the manufacturing, import, or marketing of cosmetic products are required to appoint a Responsible Technical Person. These professionals must hold a degree in chemistry, biochemistry, chemical engineering, biology, microbiology, or pharmacy.
What does a Responsible Technical Person do?
Examples of the main duties of a Responsible Technical Person include:
- Verifying the legal compliance of cosmetic products to be placed on the Turkish market.
- Ensuring that cosmetic formulations comply with Annexes II, III, IV, V, and VI of the Turkish Cosmetic Products Regulation.
- Ensuring that product labels intended to inform consumers — including product purpose, characteristics, usage, weight, and brand — comply with the Regulation, its Annexes, and relevant guidelines.
- Ensuring that a complete and up-to-date Product Information File (PIF) is available for each product.
- Informing the company in line with the Good Manufacturing Practices (GMP) Guideline.
- Performing cosmetic product notifications.
- Following up the process after cosmetic product notification.
- Informing the company about possible inspections by the Ministry and assisting the firm during the inspection process with their knowledge and expertise.
Why appoint your Responsible Technical Person through Chemleg?
Chemleg’s team includes professionals who are experts in Turkish cosmetic legislation. With our team’s expertise and Chemleg’s sectoral experience, compliance with cosmetic regulations becomes fast and effortless.
Our Responsible Technical Person service can also be integrated with Chemleg’s other services, helping you achieve full compliance.
Our Cosmetic Responsible Manager Service includes:
- Product Safety Assessment: Ensuring cosmetic products are safe for use through risk evaluations and compliance checks.
- Regulatory Compliance: Verifying adherence to Turkish and European Cosmetic Regulations.
• Product Information File (PIF) Preparation: Compiling and maintaining the mandatory Product Information File for each cosmetic product. - ÜTS Notifications: Handling product registration and notification processes.
- Labeling & Claims Review: Ensuring product labels and claims meet regulatory standards.
• Good Manufacturing Practices (GMP) Compliance: Providing guidance on GMP compliance for cosmetic production facilities.
By outsourcing Chemleg’s Responsible Technical Person service, companies can ensure full regulatory compliance while focusing on their core business operations.
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Frequently Asked Questions
Which companies must appoint a Responsible Technical Person?
All companies that manufacture, import, or place cosmetic products on the Turkish market under their own brand must appoint a Responsible Technical Person. This obligation applies to all — from small-scale producers to large importers.
What is the legal basis for the Responsible Technical Person requirement?
This requirement is directly based on the Turkish Cosmetic Products Regulation published by the Turkish Medicines and Medical Devices Agency (TİTCK) under the Ministry of Health. The Regulation clearly defines the role and responsibilities of the Responsible Technical Person to ensure the safety of cosmetic products placed on the market.
Can the company owner or partner also act as the Responsible Technical Person?
Yes. If the company owner or one of the partners holds one of the professional degrees listed in the Regulation, they may serve as the Responsible Technical Person for their own company.
How is the Responsible Technical Person officially appointed? Which documents are required?
The appointment is made through a Responsible Technical Person Contract signed between the company and the Responsible Technical Person. This appointment must be registered in the Product Tracking System (ÜTS). During registration, the following documents are typically uploaded:
- Notarized copy of the Responsible Technical Person’s diploma or graduation certificate.
- Signed contract between the company and the Responsible Technical Person outlining duties and responsibilities.
- A declaration from the Responsible Technical Person confirming acceptance of the role.
What should be done if the Responsible Technical Person resigns or is replaced?
The company must immediately update the relevant information in the ÜTS system and appoint a new Responsible Technical Person. It is not legally permitted for a company without a Responsible Technical Person to manufacture or place new products on the market.
What are the penalties for not appointing a Responsible Technical Person?
Failure to appoint a Responsible Technical Person, or providing false information about the appointment, constitutes a serious regulatory violation. If detected during inspections by TİTCK, the company may face significant administrative fines, product recalls, and even suspension of operations.