Responsible Technical Personnel

Companies that produce and sell cosmetics need an expert to be appointed by the relevant ministry and legislation to be responsible for notifications and files .

Responsible Technical Personnel , also known as the Cosmetics Responsible Manager , is more commonly referred to as the Responsible Technical Personnel in cosmetics and is one of the personnel required to be present in cosmetics companies in Turkey in accordance with the cosmetics regulation.

According to the Cosmetics Law No. 5324, the producer is a natural or legal person who produces, manufactures, improves a cosmetic product or introduces himself as a producer by putting his name, trademark or distinctive sign on the product; if the producer is outside Turkey, the representative or importer authorized by the producer; and also a natural or legal person who is in the supply chain of the product or whose activities affect the safety characteristics of the product.

One of the basic responsibilities of the manufacturer is to have a responsible technical staff (cosmetic responsible manager). According to the Cosmetics Legislation, companies cannot operate without employing a responsible technical staff and personnel with the qualifications required for the service.

The cosmetics responsible manager is responsible for ensuring the professional competence of the institution to which he/she is appointed. Therefore, it is important for the manufacturer that the person carrying out this duty follows the developments in this field and the updates in the National Cosmetics Legislation.

Thanks to our large and competent team, we not only follow domestic and international legislation, innovations and developments closely for you, but also inform you promptly with the bulletins we prepare. Entrust us with all your legal processes carried out with the Ministry of Health and enjoy being one step ahead and safe in the sector with the bulletins we prepare specifically for the companies for which we are responsible technical staff.

Who Should Employ Responsible Technical Staff ?

The definition of producer in the regulation is given as; Producers, distributors, promoters and media organizations or intermediaries that place cosmetic products on the market. Accordingly; According to Article 13 of the Cosmetics Regulation – The producer must have a responsible technical staff with the appropriate level of professional competence and the necessary experience. If the producer meets the conditions specified in the second paragraph of this article, he/she can undertake the responsible technical staff duty.

Who can be a responsible technical staff?

(Amended paragraph: RG -15/7/2015-29417 2nd duplicate) A chemist, biochemist, chemical engineer, biologist or microbiologist may be appointed as the responsible technical staff, provided that he/she can document that he/she has actually worked in the field of pharmacist or cosmetics for two years. The responsible technical staff is responsible for checking the compliance of the product to be placed on the market with the cosmetics legislation, good manufacturing practices and other relevant legislation.

Administrative fines are imposed on companies that are found not to have a responsible technical staff, pursuant to the Cosmetics Law No. 5324. Companies are required to define a responsible technical staff member since they report to the product tracking system.

Registration of Cosmetic Products to the Product Tracking System (UTS)

In order to ensure product tracking of cosmetic products before they are placed on the market in accordance with the Cosmetics Law No. 5324, the Ministry has a product tracking system. It is mandatory to notify the ÜTS platform. In addition, within the scope of Article 3 of the Cosmetics Law titled Notification and Inspection, it is mandatory to notify the Ministry of Health before the cosmetic product is first introduced to the market, and any changes that occur in the product or the manufacturer after the ÜTS registration process must also be notified.

It is prohibited to produce, package cosmetic products, open or operate an import establishment without notifying the Ministry of Health, or to expand the scope of an establishment’s activities without notifying changes made after the initial notification. A fine of twenty thousand Turkish Lira is imposed on a manufacturer who does not comply with any of these prohibitions.

No letter or document is issued by the Ministry regarding the recording of the notification regarding cosmetic products. All responsibilities specified in Laws No. 5324 and 4703 regarding the cosmetic products notified belong to the manufacturer as defined in the relevant laws.

For this reason, both the formulation and packaging (inner packaging and box design, if any) of the product registered with ÜTS must comply with the cosmetics legislation. It is of great importance that no incorrect or incomplete information is provided in the notification.”

the Product Tracking System ( UTS ) is the issuance of an export certificate (free sale certificate). Applications for export certificates for cosmetic products produced under their own brands in production facilities in Turkey by domestic cosmetic manufacturers registered with the Turkish Medicines and Medical Devices Agency, as well as cosmetic products produced with written authorization on behalf of brand-owning companies abroad, registered with the ÜTS and to be exported, are made electronically. After the Corporate Accrual payment is made, the certificate issued by the Agency (with wet signature and cold stamp) is approved and sent to the registered company address with an electronically signed cover letter. Inappropriate and/or incomplete applications are notified to the company in writing.

Sukhacos , we can undertake this entire process HYPERLINK “https://sukhacos.com/”for your brand and follow it completely. Our experienced and up-to-date team is ready to serve you.