Advertising Red Lines for Medical Devices in Turkey

1. Key takeaways

Advertising to the public is the most heavily restricted marketing activity in the Turkish device regime, and the restrictions are enforced through the dedicated sales, advertising and promotion regulation rather than through the device regulation itself. This article maps the absolute prohibition, its two exceptions, the permitted professional channels, and the numeric limits on sponsorship, so that marketing plans can be checked against the rules before any campaign is launched rather than after it has already run.

• Madde 15 paragraph 1 is an absolute prohibition: for devices restricted to use or application by healthcare professionals, and for devices within the reimbursement scope, advertising to the public, directly or indirectly, through public media including the internet is prohibited. Either trigger condition is enough; the two operate independently.
• The paragraph contains two exceptions: announcements in licensed professional publications, and product descriptions on the sales centre’s own official website. Outside these two paths, no channel of communication directed at the public is open.
• Promotion directed at professional audiences is permitted, and its boundaries are written in Madde 17 (professional journals, scientific conferences, personnel visits; technical services and clinical support do not count as promotion), Madde 18 paragraph 2 (no promotion to persons outside the above scope), and Madde 19 paragraph 6 (unpublished or incomplete clinical results must not be used for promotion).
• The quantitative limits on sponsored activities are written in Madde 21: a maximum of 3 sponsorships per person per year, and a maximum of 2 per sales centre per year; the funds must be paid to the organising body rather than to individuals; venues at seaside resorts are prohibited between 15 May and 15 October, and ski resorts between 15 November and 30 April.
• Madde 22 prohibits inducement by money, gifts or similar means. Together with the sponsorship caps, this closes off most indirect inducement routes, and any benefit flowing to a professional outside these rules should be treated as prohibited until proven otherwise.

2. Legal basis

The prohibition, the exceptions and the sponsorship limits all sit in the same dedicated regulation, whose legal basis was updated by the amending regulation of 2023. Both instruments are recorded below with the articles relied on in this article.

3. Expert insights

Insight one: devices within the reimbursement scope are an easily overlooked trigger condition. Many products are neither restricted to use by professionals nor otherwise conspicuous, yet as soon as such a product enters the SGK reimbursement lists, it automatically falls within the prohibition on advertising to the public. Before planning any marketing activity, a company must therefore first determine whether its product is within the reimbursement scope, because that determination alone can switch the entire advertising regime.

Insight two: digital channels are named expressly in the text. Madde 15 paragraph 1 writes public media including the internet directly into the provision. This means that social media, short video platforms and e-commerce product pages all fall within the category of public media. The only two compliant outlets are announcements in licensed professional publications and product descriptions on the sales centre’s own official website. Any plan that relies on other digital routes to reach the public is built on a prohibited path.

Insight three: the time windows of Madde 21 define what a compliant scientific activity looks like. Three sponsorships per person per year, two per sales centre per year, payments made to the organising body rather than to individuals, and the seasonal and venue bans on seaside and ski resorts together practically exclude tourism-style activities held in the name of science. GRZAN, when conducting compliance reviews of clients’ marketing activities, usually applies these three items directly as veto criteria, because an activity that fails any of them cannot be rescued by good documentation.

4. Practical recommendations

• Establish a three-step test for whether communication to the public is possible: is the device restricted to use by healthcare professionals; is it in the reimbursement lists; and is the channel one of the two exception paths. Only a device that passes all three steps may reach the public, and each step must be documented.
• Retain three items of evidence in the reimbursement file for each scientific activity: the participants, the receipt showing payment to the organising body, and the venue and dates (avoiding the seaside window of 15 May to 15 October and the ski window of 15 November to 30 April).
• Ensure that clinical data used in promotional materials comes only from published and completed studies (Madde 19 paragraph 6), and verify the publication status of every source before the material is released.

5. Verification checklist

• □ It has been determined whether the product falls within the prohibition of Madde 15 paragraph 1 (including devices within the reimbursement scope).
• □ Communication directed at the public is limited to the two paths of licensed professional publications and product descriptions on the sales centre’s own website.
• □ Professional promotion activities have not exceeded the channels listed in Madde 17.
• □ Scientific sponsorship has not exceeded 3 per person / 2 per sales centre per year, and has not touched the restricted venues and seasons.
• □ Promotional materials do not use unpublished or incomplete clinical results.

Regulatory information verified as of 29 October 2026. The provisions and limit figures cited in this article were checked against the original texts of the Turkish Official Gazette and the legislative information system.

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support for the Turkish market. Our team coordinates authorised representative and importer arrangements, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com