Law No. 7223 on Product Safety and Technical Regulations requires manufacturers to place only safe products that comply with their technical regulations on the Turkish market. To that end, the technical file and conformity documents are prepared and kept for at least ten years, the product carries a model, batch or serial number, complaints and recalls are recorded, and the details of the previous and next operator in the supply chain are kept for ten years. Counterfeiting conformity markings and documents is prohibited. For 2026, the administrative fine bands in paragraph 1 of Article 20 range from TRY 60,830 to TRY 4,345,058.
Who and which products does the law cover?
The law covers all products intended to be placed on the market, placed on the market, made available or put into service. It was published in the Official Gazette on 12 March 2020 and entered into force one year later. Where a specific law exists for a product, Law No. 7223 applies to matters that law does not cover.
There are two separate rules for exports. Products exported or intended for export to EU member states are deemed to have been placed on the market under the law. Products exported to countries outside the EU fall outside its scope, but they must still be safe, must not be adulterated, and their marking, labelling and certification must not mislead the buyer.
The law divides obligations among four economic operators: the manufacturer, the authorized representative, the importer and the distributor. Where a product has no technical regulation, or its regulation has no provisions on human health and safety, safety is assessed under the general product safety legislation.
What are the manufacturer's obligations?
Under Article 7, the manufacturer:
- Places on the market only products that comply with their technical regulation or with the general product safety legislation.
- Where the legislation requires it, draws up the technical file, carries out or commissions the conformity assessment, issues the declaration of conformity and affixes the conformity marking.
- Keeps the technical file and documents for the period set in the technical regulation or, if none is set, for at least ten years from placing the product on the market.
- Takes the measures needed to keep series production in conformity.
- In proportion to the risk, samples and tests products on the market and keeps a record of complaints and of non-conforming and recalled products.
- Ensures the product carries, in an easily visible and legible form, the model, batch and serial number required by the legislation or other information that allows it to be identified. Where the product's size does not allow this, the information goes on the packaging or an accompanying document.
- States its name, trade name or trademark and full address on the product, packaging or accompanying document.
- Provides warnings, instructions for use and maintenance, and safety rules in Turkish.
- On learning that a product is non-conforming, promptly takes corrective measures, including withdrawal or recall where necessary, and informs the competent authority where there is a risk.
Two items on this list are directly about records: keeping documents for ten years, and making the product identifiable by batch or serial number.
What is expected of importers and distributors?
Before placing a product on the market, the importer confirms the conformity marking, the required documents, and that the manufacturer has met its document, numbering and address obligations. It also states its own name and address on the product, packaging or document, keeps a copy of the documents available to the competent authority for at least ten years, and keeps a record of complaints and recalls.
Before making a product available, the distributor verifies the conformity marking, the documents, the Turkish instructions and the manufacturer's and importer's numbering and address details. It may not make available a product it knows to be non-conforming.
Who counts as the manufacturer?
Article 11 extends the roles. An importer or distributor that places a product on the market under its own name or trademark, or modifies it in a way that affects its conformity, is treated as the manufacturer and becomes responsible for all of the obligations in Article 7. The definition of manufacturer is also broad: under Article 3, a person who has a product designed or manufactured and places it on the market under its own name or trademark is a manufacturer. A company selling own-brand products made by a contract manufacturer is therefore directly subject to Article 7.
If the manufacturer, authorized representative or importer cannot be identified, a distributor that does not report their details, or failing that the details of the previous operator in the supply chain, within ten working days of the competent authority's notice is also treated as the manufacturer.
What does the traceability obligation require?
Article 12 gives every economic operator the same record-keeping duty: the name, trade name or trademark and contact details of the previous and, where applicable, the next operator in the supply chain, and other information that makes the product easier to trace, are recorded regularly, kept for at least ten years from placing the product on the market, and provided at the competent authority's request. The obligation also applies to those selling products online, to e-commerce intermediary service providers, and to media service providers such as radio and television.
This is a model in which each link knows its two neighbours. We describe the equivalent principle in food law in our traceability article.
Why is counterfeiting of conformity markings regulated separately?
Paragraph 2 of Article 13 prohibits issuing, using, falsifying or counterfeiting, contrary to the truth, any conformity marking, certificate, test report or other document relating to products covered by a technical regulation. Conformity markings may be used only on products for which a technical regulation provides for them, and no other marking that misleads about their meaning or form may be placed on the product.
A counterfeit often copies the conformity marking along with the brand. In that case, the ban on counterfeiting markings under Law No. 7223 comes into play alongside trademark infringement. We cover the trademark side in our article on fighting counterfeit products.
How large are the administrative fines in 2026?
The amounts in Article 20 are updated each year by the revaluation rate. The 2026 values were set by Communiqué on Product Safety and Inspection No. 2026/13, published in Official Gazette No. 33124 (4th duplicate issue) of 31 December 2025, and apply from 1 January to 31 December 2026. The amounts incorporated in the text on mevzuat.gov.tr are:
| Infringement (Article 20/1) | 2026 amount (TRY) |
|---|---|
| (a) Breach of the product safety provisions of the technical regulation or general product safety legislation (7/1-a, 9/1-a) | 434,505 - 4,345,058 |
| (b) Breach of the other provisions of the same legislation | 173,801 - 1,738,022 |
| (c) Technical file, conformity assessment and marking (7/1-b, 9/1-b) and counterfeiting of conformity markings and documents (13/2) | 173,801 - 1,738,022 |
| (ç) Obligations such as conformity in series production, sampling and complaint records, and corrective measures (7/1-ç, d, g, h, ı and others) | 86,900 - 869,010 |
| (e) Ten-year document retention, batch and serial number, name and address, Turkish information (7/1-c, e, f, ğ, i), traceability records (12) and others | 60,830 - 608,307 |
Three rules in the same article matter in practice:
- For infringements under sub-paragraphs (c), (ç), (d) and (e), sub-paragraphs (a) and (b) are not applied in addition for the same act.
- If the non-conformity recurs within two years, each repetition is fined at twice the previous fine.
- In setting the fine, the scale of the infringement and the economic situation of the person fined are taken into account.
According to the Ministry of Trade's 2025 market surveillance report, administrative fines imposed on non-compliant products in 2025 totalled TRY 3,773,689,932. We cover how inspections are divided among authorities in our article on market surveillance.
Who is liable if a product causes damage?
Under Article 6, if a product damages a person or property, the manufacturer or importer must compensate the damage. The injured party proves the damage and the causal link between the non-conformity and the damage. Where more than one manufacturer or importer is responsible, they are jointly and severally liable, and contract terms that remove or reduce this liability are void. The limitation period is three years from when the injured party learns of the damage and the liable party, and in any case ten years from when the damage occurred.
What releases an operator from liability?
Article 21 sets out two situations. An operator that detects a non-conformity itself, without a request from the competent authority, takes the necessary measures including recall on its own initiative and fully remedies the non-conformity is not subject to administrative sanctions.
The second situation matters for counterfeits. If the manufacturer or importer proves that it did not place the product on the market itself, that the non-conformity results from interference by the distributor or a third party, or that it arises from manufacturing the product in line with technical regulations, no administrative sanction applies and the compensation liability under Article 6 ends. When a counterfeit bearing your brand turns out to be unsafe, being able to show that the product is not one you made is the precondition for relying on this provision. What proves it is the product's batch-level or unit-level identity and the record tied to it.
How do records meet these obligations?
Most of the records the law asks for come from the same data: the product's batch or serial number, the production and document records that number is tied to, and who the shipment went to. We explain the choice between batch and serial numbers in our GS1 article. How we give a product a traceable identity and build it together with verification is described on our tracking, tracing and verification service page.
Frequently asked questions
When did Law No. 7223 enter into force?
It was published in the Official Gazette on 12 March 2020 and entered into force one year after publication, on 12 March 2021.
How long must the technical file be kept?
For the period set in the technical regulation or, if none is set, for at least ten years from placing the product on the market.
What is the highest fine band in 2026?
The band for breaching product safety provisions, from TRY 434,505 to TRY 4,345,058. If the non-conformity recurs within two years, each repetition is fined at twice the previous fine.
Are products exported outside the EU subject to the law?
Products exported to non-EU countries fall outside its scope, but they must be safe, must not be adulterated, and their marking, labelling and certification must not mislead the buyer. Products exported to the EU are deemed to have been placed on the market.
Do online sellers have these obligations too?
Yes. The traceability obligation in Article 12 expressly covers those selling online and e-commerce intermediary service providers; the details of distance sales are set out in a separate regulation.
This article is for general information. Fine amounts are updated every year; in a specific case, the current text of the legislation should be checked and legal advice sought.
Sources
- Law No. 7223 on Product Safety and Technical Regulations, text with 2026 fine amounts (Articles 2, 6, 7, 9, 10, 11, 12, 13, 20, 21, 26), in Turkish
- Law No. 7223, Legislation Information System page, in Turkish
- General Product Safety Regulation, Official Gazette, 11 March 2021, No. 31420, in Turkish
- Ministry of Trade, Market Surveillance and Inspection 2025 Report, in Turkish
