Introduction
Product safety and recall obligations are essential components of consumer protection in Turkey. A consumer does not only expect a product to work properly; the consumer also expects the product to be safe. A toy should not contain harmful substances, an electrical product should not create fire risk, a cosmetic product should not endanger health, a furniture item should not collapse during ordinary use, a baby product should not create choking risk, and a household appliance should not expose users to electric shock.
Turkish law regulates product safety through a combination of consumer protection rules, technical regulations, market surveillance mechanisms, administrative sanctions, recall procedures, and compensation principles. The main legal framework includes Law No. 7223 on Product Safety and Technical Regulations and Law No. 6502 on the Protection of Consumers. Law No. 7223 focuses on product safety, technical compliance, market surveillance, corrective measures, withdrawal from the market, recall, and liability for damage caused by unsafe products. Law No. 6502 protects consumers in ordinary consumer transactions, including defective goods, refund claims, replacement, repair, price reduction, and compensation.
The Ministry of Trade explains that all products placed on the market or intended to be placed on the market must be safe. A product complying with technical regulations relating to human health and safety is presumed safe unless proven otherwise; where no technical regulation exists, safety may be assessed according to international standards, national standards, good practice codes, and sector-specific rules.
This article explains how product safety and recall obligations work in Turkey, who is responsible, what happens when an unsafe product is detected, what rights consumers have, how recall announcements are made, how product safety differs from ordinary defective goods claims, and how consumers and businesses should act in product safety disputes.
What Is Product Safety Under Turkish Law?
Product safety means that a product must not create unacceptable risks for human health, life, property, animals, plants, the environment, or consumers when used under normal or reasonably foreseeable conditions. A product does not need to cause actual injury before it becomes legally problematic. If the product carries a serious risk, it may trigger regulatory action even before harm occurs.
For example, a toy containing excessive chemical substances, a charger that overheats, a baby stroller with structural instability, a cosmetic product containing prohibited ingredients, a detergent with improper labeling, a school supply containing unsafe material, or an electrical device that lacks required technical compliance may be treated as unsafe.
Law No. 7223 is important because it does not only regulate what happens after consumers are injured. It also creates a preventive system. Products can be inspected, tested, restricted, withdrawn from the market, recalled from consumers, or announced through official channels before wider damage occurs. The Ministry of Trade identifies market surveillance and inspection legislation as part of the consumer protection and product safety framework and lists Law No. 7223, the Market Surveillance and Inspection Regulation of the Ministry of Trade, the General Product Safety Regulation, and product-specific regulations such as toy safety, detergents, textile labeling, and footwear labeling rules.
Product Safety vs. Defective Goods
Product safety and defective goods are related but different legal concepts. A product may be defective because it does not conform to the contract, does not match the advertised features, does not perform as promised, or lacks expected economic or functional value. Product safety, on the other hand, concerns whether the product creates a risk to health, safety, property, or other protected interests.
For example, a mobile phone with a weak battery may be defective. If the battery overheats and creates fire risk, the issue may also become a product safety problem. A chair with poor finishing may be defective. A chair that collapses during ordinary use may also be unsafe. A cosmetic product with different packaging than advertised may be defective. A cosmetic product containing harmful substances may be unsafe.
Under Law No. 6502, a consumer may use elective rights for defective goods, including refund, price reduction, free repair, or replacement. The Ministry of Trade explains that goods lacking promised characteristics, contradicting the seller’s statements or technical rules, or containing material, legal, or economic deficiencies reducing expected benefit may be treated as defective; the consumer has four elective rights, and the seller must fulfill the consumer’s chosen remedy.
However, where a product violates technical safety rules, the matter may go beyond a private refund dispute. Regulatory authorities may impose market withdrawal, recall, corrective action, public announcements, and administrative sanctions. A consumer may still claim refund or compensation, but the public safety dimension becomes central.
Scope of Turkish Product Safety Law
Law No. 7223 has a broad scope. The Ministry of Trade states that the law principally covers all products, although if a specific product is regulated by a special law, Law No. 7223 applies where the special law has no provision. This is because special laws may contain more detailed rules for particular product categories.
This broad scope is important because consumer products are diverse. Product safety may concern toys, textiles, detergents, furniture, bicycles, sports equipment, helmets, lighters, stationery, candles, baby products, electrical devices, machinery, cosmetics, medical devices, construction materials, personal protective equipment, telecommunication equipment, fuels, and many other products. The competent authority may vary depending on the product group. For example, the Ministry of Trade is responsible for areas such as toys, detergents, stationery, furniture, and textiles, while other authorities may be responsible for food, medical devices, machinery, motor vehicles, cosmetics, personal protective equipment, telecommunication equipment, or building materials.
Therefore, a product safety dispute must begin with identifying the product category and the competent public authority. A toy, a cosmetic product, a medical device, a food product, and an electrical appliance may require different technical rules and different administrative authorities.
Market Surveillance and Inspection in Turkey
Market surveillance and inspection is the public mechanism used to check whether products placed on the market comply with technical regulations and general product safety requirements. Authorities may inspect products, request documents, conduct tests, evaluate risks, order corrective measures, prohibit sale, withdraw products from the market, or require recall.
The Ministry of Trade explains that competent authorities may take significant measures during market surveillance and inspection, including product collection, prohibition of market supply, and administrative fines. The Ministry also emphasizes that market surveillance must be carried out in the public interest, without profit motive and without conflicts of interest.
For businesses, this means that product safety compliance is not optional. A manufacturer, importer, distributor, or online seller may face regulatory scrutiny even without an individual lawsuit. For consumers, market surveillance provides an official channel for unsafe product complaints, especially where the issue affects public safety.
Who Is Responsible for Product Safety?
Product safety law uses the concept of “economic operators,” which may include manufacturers, importers, authorized representatives, distributors, and other parties involved in placing products on the market or making them available. Each actor’s responsibility depends on its role in the supply chain.
A manufacturer is generally responsible for designing, producing, and placing safe and compliant products on the market. An importer may be treated with a high level of responsibility because it introduces foreign products into the Turkish market. A distributor must not supply products where it knows or should know that the product is unsafe or non-compliant. A seller may also become relevant if it sells products to consumers despite safety concerns, fails to transmit recall information, or ignores official measures.
The Ministry of Trade identifies one of the innovations of Law No. 7223 as the separate definition and clarification of the roles and responsibilities of economic operators placing products on the market. It also notes that product traceability was regulated and that the recall mechanism became a legal requirement even where unsafe products had already been sold to consumers.
This supply-chain logic is important in litigation. A consumer harmed by an unsafe product should not look only at the retail seller. Depending on the facts, the manufacturer, importer, distributor, seller, marketplace platform, or service provider may all need to be examined.
Product Traceability and Documentation
Product traceability is a central element of safety compliance. If an unsafe product is discovered, authorities and businesses must identify where the product came from, which batches are affected, where it was sold, and how consumers can be reached. Without traceability, recall may become ineffective.
Businesses should preserve documents such as supplier records, import documents, conformity declarations, test reports, batch numbers, production dates, serial numbers, technical files, invoices, distribution lists, marketplace listings, customer order records, and complaint records.
Traceability is especially important for online sales. If a product is sold through an e-commerce platform, the platform and seller should be able to identify product listings, sellers, buyers, shipment dates, batches, and customer communications. The Ministry of Trade specifically notes that Law No. 7223 includes important provisions to enable effective supervision of products sold through the internet, radio, and television.
What Is Product Withdrawal?
Product withdrawal means removing an unsafe product from the market before it reaches or continues to circulate among consumers. Withdrawal is directed at products within the supply chain. For example, a distributor may remove products from warehouses, stores, shelves, or online listings after discovering a safety problem.
The Ministry of Trade explains the difference between withdrawal and recall as follows: withdrawal means that economic operators, either voluntarily or upon the request of the competent authority, remove an unsafe product from the market, while recall is directed at getting the product back from consumers or end users. The key difference is whether the product is being taken back from consumers or end users.
Withdrawal is generally more preventive. If unsafe products are still in stores or warehouses, they should be blocked before reaching more consumers. Recall becomes necessary when products have already reached consumers or end users and the risk cannot be eliminated through lesser measures.
What Is Product Recall?
A product recall is a corrective measure aimed at bringing an unsafe product back from consumers or final users to the responsible economic operator. Recall may be voluntary or ordered by the competent authority. It is usually required when other measures are insufficient to eliminate the risk.
Law No. 7223 treats recall as a serious consumer protection mechanism. The Ministry of Trade explains that one of the innovations of the law is that unsafe products must be collected through the recall mechanism even where they have already been sold to consumers.
Recall can apply to many product categories. Examples may include toys with chemical risks, children’s products with choking risks, electrical appliances causing fire risk, textile products containing prohibited substances, furniture with structural risk, cosmetics causing health risk, or sports equipment that fails during use.
A recall should be clear, accessible, and effective. A hidden website notice is usually not enough if the product was widely distributed. Consumers should be able to identify the product, understand the risk, learn what they should do, and access remedy options without unreasonable burden.
What Must a Recall Announcement Include?
Recall and product safety announcements should allow consumers to identify the product and understand the risk. Under product safety practice, a corrective measure announcement may include product brand, model, type, distinguishing features, product photo or visual description, the measure taken, the problem requiring the measure, responsible business information, and recommended methods to avoid the risk or solve the problem.
The Ministry of Trade’s corrective action guidance for unsafe products refers to recall announcements and states that announcement text must be shared through the distribution chain and placed where easily visible or accessible. It also lists announcement methods such as direct notification, phone, SMS, email, post, website publication for at least one year, newspaper notice, or television notice.
The form of announcement should match the product’s distribution channel and risk level. If a product was sold nationally through online marketplaces, the recall should not be limited to a local notice. If customer records are available, direct notification may be necessary. If the product creates serious health risk, broader publication may be required.
Consumer Options in a Recall
When a product is recalled, the final user should not be left without an effective remedy. Under Law No. 7223, the economic operator must offer at least one of several options to the final user who delivers the product: elimination of the problem causing the recall, payment of the product’s retail value at the delivery date, or replacement with a safe and equivalent product compliant with the technical regulation. The law also provides that all recall-related expenses must be borne by the economic operator conducting the recall and that the final user should not face additional cost in delivering the product.
These options are important because recall should not become an additional burden on consumers. A consumer should not have to pay cargo fees, repair fees, service fees, or other costs merely to participate in a safety recall. The responsible business should create a practical, accessible, and cost-free process.
For consumers, the best approach is to keep purchase documents, product photos, serial numbers, batch numbers, packaging, recall notices, and communication records. Even if the invoice is missing, product identification may still be possible through serial number, batch number, or seller records.
GÜBİS: Unsafe Product Information System
Turkey uses the Güvensiz Ürün Bilgi Sistemi, commonly known as GÜBİS, as a public platform where unsafe products detected by competent market surveillance authorities are announced. The platform states that GÜBİS is used to publish products found unsafe by authorized market surveillance and inspection institutions. It also clarifies that notifications relate only to the specific product subject to the notification and do not automatically mean that the producer’s other products are unsafe.
Consumers can check GÜBİS when they suspect a product is unsafe or when they want to verify whether a recall has been announced. Businesses should monitor such systems and respond quickly if their products are listed or if similar products in their sector create risk signals.
GÜBİS is especially useful for consumers who bought products online or from small retailers and later discover safety concerns. It helps identify whether an official safety decision already exists.
How Consumers Can Report Unsafe Products
Consumers who suspect that a non-food product is unsafe may submit complaints through official channels. The Ministry of Trade’s regional market surveillance page states that unsafe non-food product complaints may be submitted through CİMER or by direct petition to the relevant group presidency for product groups within that authority’s competence.
A consumer complaint should be practical and evidence-based. It should include product name, brand, model, serial number, batch number, purchase date, seller identity, invoice or receipt, photographs, description of the risk, injury or damage if any, and any correspondence with the seller or manufacturer.
Consumers should avoid continuing to use a product suspected of being unsafe, especially where the risk involves fire, electric shock, chemical exposure, child safety, structural collapse, or injury.
Product Safety and Compensation Claims
Product safety law is not limited to administrative action. If an unsafe product causes injury, death, or damage to another product, compensation claims may arise. The Ministry of Trade identifies one of the innovations of Law No. 7223 as manufacturer or importer liability toward the injured person for death, personal injury, or damage to another product caused by an unsafe product.
For example, if an unsafe electrical appliance causes fire damage, if a defective baby product injures a child, if a cosmetic product causes serious harm due to prohibited ingredients, or if a household item collapses and causes injury, the injured person may seek compensation.
A compensation claim usually requires proof of the unsafe product, damage, causal link, and legally responsible party. Evidence may include medical reports, expert reports, photographs, fire department reports, product testing, purchase documents, witness statements, repair invoices, and official recall announcements.
Relationship Between Product Safety and Consumer Remedies
A consumer affected by an unsafe product may have several possible remedies. If the product is also defective under Law No. 6502, the consumer may request refund, price reduction, free repair, or replacement. If the product is recalled under Law No. 7223, recall-specific options may apply. If the product caused damage, compensation may be claimed. If the product was advertised misleadingly as safe, certified, child-friendly, organic, medical, or compliant, advertising and unfair commercial practice rules may also become relevant.
The consumer’s legal strategy should therefore separate:
Product safety complaint to public authorities
Recall participation
Defective goods claim against seller, manufacturer, or importer
Compensation claim for injury or property damage
Complaint about misleading advertising
Consumer Arbitration Committee or Consumer Court route
Possible expert examination
A simple refund request may not be enough where the product created serious risk. Conversely, a regulatory complaint alone may not recover the consumer’s personal financial loss. Both paths may be necessary.
Online Marketplaces and Product Safety
Online marketplaces are increasingly important in product safety disputes. Unsafe products may be sold by third-party sellers through marketplace platforms. These products may include toys, electronics, cosmetics, baby products, small appliances, furniture, sports equipment, or imported goods.
Marketplaces should have systems to identify unsafe listings, respond to official notices, remove dangerous products, inform consumers, and cooperate with authorities. Sellers should not assume that product safety duties disappear because the sale occurs online. The Ministry of Trade expressly notes that Law No. 7223 includes provisions to ensure effective supervision of products sold through internet, radio, and television channels.
Consumers buying through online marketplaces should preserve product listings, seller profiles, order confirmations, invoices, cargo records, and product photos. If a recall is announced, the consumer should also save recall notices and platform communications.
Product Safety in Import Transactions
Importers play a crucial role because many consumer products in Turkey are imported. An importer may be responsible for ensuring that the product complies with Turkish technical regulations before placing it on the market. Import documents, conformity documents, test reports, labeling, user manuals, and Turkish-language warnings may become important evidence.
Imported products that lack proper Turkish labeling, warnings, conformity markings, technical documentation, or safe design may create both administrative and civil liability. If the foreign manufacturer is difficult to reach, the importer may become the primary responsible party in Turkey.
Businesses importing consumer products should conduct compliance checks before sale. A low-cost imported product may become legally expensive if it later triggers recall, administrative fines, product liability claims, or compensation lawsuits.
Product Safety and Warnings/User Manuals
A product may be unsafe not only because of its physical design but also because of inadequate warnings or instructions. If ordinary consumers cannot understand how to use the product safely, the product may create foreseeable risk.
Examples include electrical products without Turkish safety instructions, children’s products without age warnings, cosmetics without ingredient or usage warnings, cleaning products without hazard information, furniture without assembly safety instructions, or sports equipment without protective use instructions.
Warnings should be clear, visible, understandable, and suitable for the consumer group likely to use the product. If the product is intended for children, elderly users, household users, or non-professional consumers, the warning standard may be stricter in practice.
Evidence in Product Safety Disputes
Evidence is critical in product safety disputes. Consumers should preserve:
Invoice or receipt
Product packaging
User manual
Warranty certificate
Serial number, batch number, model number
Photos and videos of the product
Photos of warning labels
Screenshots of online product pages
Cargo and delivery records
Medical records if injury occurred
Repair reports
Expert reports
Fire, accident, or incident reports
Correspondence with seller, importer, manufacturer, or platform
Recall notice
GÜBİS record, if available
Witness statements
Damaged property photos and invoices
Consumers should avoid destroying or repairing the product before evidence is collected, unless necessary for safety. If the product created serious risk, it should be stored safely and not used.
Businesses should preserve technical files, conformity documentation, test reports, production records, batch records, supplier records, import documents, complaints, corrective action plans, distribution lists, and recall communications.
Consumer Arbitration Committees and Product Safety-Related Refund Claims
If the consumer’s claim is mainly a refund, replacement, repair cost, or price reduction claim and falls below the annual monetary threshold, Consumer Arbitration Committees may be relevant. For 2026, the Ministry of Trade states that disputes below TRY 186,000 must be brought before Provincial or District Consumer Arbitration Committees, while disputes of TRY 186,000 or more cannot be decided by those committees and must proceed through mandatory mediation and Consumer Courts or civil courts acting as Consumer Courts.
Applications can be made personally or through an attorney, by hand, by post, or electronically through e-Government via TÜBİS. Oral applications are not accepted, and the application must include the dispute, request, value in Turkish lira, and supporting documents.
However, if the dispute involves serious injury, high-value property damage, complex technical evidence, manufacturer liability, or compensation beyond ordinary refund, Consumer Court litigation or other legal routes may be necessary.
Consumer Courts and Product Liability Litigation
High-value product safety disputes often require court proceedings. These may involve personal injury, death, fire damage, major property loss, unsafe machinery, dangerous electronics, defective children’s products, or harmful cosmetics. Expert examination is usually central.
A strong court petition should identify:
The product and its technical details
The manufacturer, importer, seller, and distributor
The applicable technical regulation or safety standard
The defect or risk
The injury or damage
The causal link
Official recall or GÜBİS record, if any
Consumer-law remedies requested
Compensation amount and supporting evidence
If the product is no longer available because it was destroyed in an accident or fire, secondary evidence such as photographs, invoices, witness statements, official reports, service records, and product model documents become more important.
Practical Advice for Consumers
Consumers should stop using a product immediately if they suspect serious safety risk. They should photograph the product, serial number, label, packaging, and defect. They should check whether the product appears on GÜBİS or another official recall notice. They should notify the seller, manufacturer, importer, or platform in writing.
If injury or property damage occurred, the consumer should obtain medical records, official incident reports, repair estimates, and expert evaluation where necessary. For unsafe non-food products, complaints can be submitted through CİMER or relevant authority channels.
Consumers should not accept informal solutions that require them to waive compensation rights without legal evaluation, especially where injury or serious damage occurred.
Practical Advice for Manufacturers, Importers, and Sellers
Businesses should treat product safety as a compliance system, not a crisis response. Before placing a product on the market, they should verify applicable technical regulations, conduct conformity assessments, prepare Turkish labels and manuals, preserve technical files, monitor complaints, and maintain traceability.
If a risk is detected, businesses should act quickly. They should stop sale where necessary, inform authorities, identify affected batches, notify distributors and consumers, prepare corrective action plans, and implement withdrawal or recall if required. Recall announcements should be clear, accessible, and effective.
Businesses should also train customer service teams. A consumer complaint about overheating, chemical odor, injury, electric shock, child safety, or fire risk should not be treated as an ordinary dissatisfaction complaint.
Conclusion
Product safety and recall obligations under Turkish consumer protection law create a strong framework for protecting consumers against unsafe products. Law No. 7223 requires products placed on the market or intended to be placed on the market to be safe, clarifies the roles of economic operators, regulates traceability, creates recall mechanisms, and allows public authorities to take measures such as market withdrawal, recall, sale prohibition, and administrative sanctions.
Product safety should be distinguished from ordinary defective goods. A product that does not work properly may be defective; a product that creates health or safety risk may also trigger market surveillance, official recall, and product liability. Consumers may have remedies under both Law No. 6502 and Law No. 7223, including refund, replacement, repair, recall participation, and compensation where damage occurs.
For consumers, the strongest strategy is documentation: preserve invoices, photos, packaging, serial numbers, medical records, expert reports, recall notices, and communications. For businesses, the safest strategy is preventive compliance: verify technical regulations, maintain traceability, monitor complaints, cooperate with authorities, and conduct effective recalls when necessary.
In Turkey, product safety is not merely a quality issue. It is a legal obligation connected to public health, consumer protection, market surveillance, administrative enforcement, and civil liability. A safe product protects consumers; a proper recall protects both the public and the responsible business from greater harm.
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