Technical Service and After-Sales Obligations in Turkey

1. Key takeaways

Turkey has legislated after-sales technical service as a standalone subject matter. A dedicated regulation governs the qualification, authorisation and supervision of technical service providers, while the sales regulation draws the boundary between legitimate technical service and prohibited promotion. Together these two instruments define what a compliant service operation in Turkey must look like.

• Turkey has given after-sales service its own law: the Regulation on Technical Service Services for Medical Devices Used Within the Scope of Health Service Provision (Sağlık Hizmet Sunumu Kapsamında Kullanılan Tıbbi Cihazların Teknik Servis Hizmetlerine Dair Yönetmelik), published in the Resmî Gazete on 26 May 2023 in issue 32202, on the same day as the amending regulation to the Regulation on Sales, Advertising and Promotion of Medical Devices.
• The regulation governs the qualification, authorisation and supervision of technical service entities. This has direct significance for companies: an entity undertaking installation, calibration or repair of equipment in Turkey is no longer an ordinary service vendor but an object bound by a dedicated regulation.
• An important boundary rule is written in Madde 17 of the sales regulation: technical service and clinical support do not constitute promotion. This gives companies a legitimate space for professional activity that does not fall into the advertising prohibition clauses.
• The resulting compliance combination is this: technical service as such is permitted, but the entity performing it must hold the required qualification, and it must not use technical service as a vehicle for public-facing communication prohibited by Madde 15 paragraph 1.

2. Legal basis

Two instruments define the framework: the dedicated technical service regulation of 2023 and the sales regulation, whose promotion boundary and public communication prohibition delimit what service personnel may and may not do. Their identifying details are recorded below.

3. Expert insights

Insight 1: after-sales service has been upgraded from a contract clause to a regulatory object. In many markets, after-sales arrangements can be settled entirely in the distribution contract; Turkey has handed the subject to a dedicated regulation. For exporters of active equipment, imaging equipment and large in vitro diagnostic systems, this means that the selection of the service network must take qualification compliance into account, not only price and response speed. A cheaper unqualified provider is not a saving but a liability, because the service relationship itself falls within the scope of the regulation.

Insight 2: Madde 17 draws a clear safe zone for companies. Madde 17 of the sales regulation excludes technical service and clinical support from the concept of promotion. This exclusion has real value: within a framework that prohibits advertising to the public, a company can still maintain end-user relationships through legitimate technical service and clinical support. The precondition is that these activities carry no promotional content. The boundary is functional, not formal, so service reports, training materials and field communications all need review to ensure they stay on the service side of the line.

Insight 3: 26 May 2023 is a same-day, two-document node. On the same day and in the same issue, the amendment to the sales and advertising regulation and the technical service regulation were both published. Synchronised publication of this kind usually signals a regulatory intent to tighten and govern the sales line and the after-sales line together, as one programme. Compliance scheduling should therefore treat the two as a group rather than handling them separately, and any internal gap analysis should cover both instruments in the same pass.

Insight 4: the qualification requirement changes how service capability is planned. Because the technical service regulation governs qualification, authorisation and supervision, building a service network in Turkey is no longer a matter of hiring technicians and issuing toolkits. The provider entity itself must stand within the regulatory frame, and its authorisation status becomes part of the manufacturer’s own compliance picture. Exporters should therefore map their installed base against the service providers actually assigned to it, and treat any change of provider as a compliance event requiring re-verification rather than a purely commercial substitution.

4. Practical recommendations

• When selecting a service provider in Turkey, write the question of whether the provider holds the technical service qualification required under the Sayı 32202 regulation into the due diligence checklist.
• Make explicit in service contracts that service activities do not involve public-facing communication, and route all communication actions through the professional channels listed in Madde 17.
• Maintain a service record ledger covering the service recipient, date, content and personnel, kept ready for inspection.
• Review service deliverables such as reports and training materials for promotional content before release, keeping the boundary of Madde 17 intact.

5. Verification checklist

• □ The applicable regulation for technical service has been confirmed as Sayı 32202 (2023-05-26).
• □ The service provider holds the corresponding technical service qualification and authorisation.
• □ Service activities carry no public-facing advertising content (with reference to Madde 15 paragraph 1).
• □ Madde 17 has been cited to distinguish technical service and clinical support from promotion.
• □ A service record ledger has been established and can be retrieved on demand.

Regulatory information verified as of 29 October 2026. The names, issue numbers and dates of the regulations cited in this article were checked against the original texts of the Resmî Gazete; the internal qualification classifications of the technical service regulation were not obtained provision by provision, and the related content is treated as a practical estimate.

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 manages adverse event reporting and recall coordination with TITCK, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com