Introduction
Health-related advertising is one of the most sensitive areas of Turkish advertising law. Consumers may rely on advertisements when making decisions about food supplements, cosmetics, medical devices, healthcare services, wellness products, weight-loss programs, aesthetic procedures, herbal products, vitamins, skincare products and other goods or services that may affect health, appearance or well-being. For this reason, health claims in advertising in Turkey are subject to strict legal control.
A health claim can be extremely persuasive. If a product is advertised as strengthening immunity, curing a disease, reducing pain, improving sleep, supporting weight loss, preventing illness, treating skin problems, eliminating wrinkles, increasing fertility or improving mental performance, consumers may make purchasing decisions based on that claim. If the claim is false, exaggerated, unsupported or legally unauthorized, it may harm not only consumer economic interests but also public health.
Turkish advertising law does not prohibit all health-related statements. However, such claims must be lawful, accurate, substantiated, clear and compliant with sector-specific legislation. A business cannot freely use medical, therapeutic or disease-related expressions merely because they are commercially effective. The legal standard is stricter where the advertisement targets vulnerable consumers such as patients, elderly persons, children or people with health concerns.
The main legal framework is based on Law No. 6502 on the Protection of Consumers, the Regulation on Commercial Advertising and Unfair Commercial Practices, the decisions of the Advertising Board and sector-specific rules applicable to medicines, medical devices, food supplements, cosmetics, health services and similar products. The Ministry of Trade states that advertisements for medicines, human medicinal products, medical devices, health services, foods, food supplements, cosmetics, cleaning products, biocidal products, tobacco products and alcoholic beverages must also comply with the advertising and promotion provisions in their own specific legislation.
The importance of this topic is reflected in enforcement practice. The Advertising Board’s 342nd meeting, held on 13 February 2024, focused mainly on advertisements concerning consumer health, especially food supplements, foods, cosmetics and healthcare services. In that meeting, 185 files were reviewed, 157 were found unlawful, and 47 health-related files resulted in administrative fines totaling 9,126,735 TL.
This article explains the legal restrictions on health claims in advertising in Turkey, the difference between lawful information and unlawful health claims, sector-specific risks, influencer marketing issues, e-commerce advertising, consumer testimonials, scientific substantiation, Advertising Board sanctions and practical compliance steps for businesses.
What Is a Health Claim in Advertising?
A health claim is any statement, expression, image, symbol, testimonial or implication suggesting that a product, service or ingredient has a relationship with human health. The claim may be direct, such as “this product treats joint pain,” or indirect, such as “feel younger,” “support your immune system,” “detox your body,” “protect your heart,” or “restore your natural balance.” In Turkish advertising law, the overall impression created by the advertisement is important. Even if the advertisement avoids explicit medical wording, it may still be considered a health claim if consumers understand it as suggesting a health-related benefit.
Health claims may appear in many forms. They may be written in product descriptions, shown in visuals, communicated by influencers, implied through before-and-after images, stated in consumer testimonials, included in e-commerce Q&A sections, supported by doctor-like figures, or suggested through scientific-looking graphics. A health claim may also arise from a brand name, product name, slogan, packaging design or search advertisement.
For example, the following expressions may create legal risk if not properly authorized and substantiated:
“Helps treat diabetes.”
“Prevents viral infections.”
“Cures acne.”
“Clinically proven to eliminate wrinkles.”
“Natural solution for joint pain.”
“Doctor recommended.”
“Strengthens immunity.”
“Permanent weight loss.”
“Reduces anxiety.”
“Detoxifies the liver.”
“Alternative to medication.”
“Repairs damaged cells.”
The legal issue is not only whether the statement is medically correct. The question is also whether the advertiser is legally allowed to make such a claim for that product or service and whether the claim is supported by reliable evidence. A food supplement, for example, cannot be advertised as a medicine. A cosmetic product cannot be promoted as if it treats a disease. A wellness service cannot promise guaranteed therapeutic results.
Main Legal Principles Governing Health Claims
The first principle is truthfulness. Health-related advertisements must not contain false, exaggerated or deceptive statements. A product cannot be advertised as having therapeutic effects if such effects are not legally recognized and scientifically supported.
The second principle is substantiation. Objective, measurable and numerical claims must be proven by scientific tests, reports or documents. The Ministry of Trade’s consumer information guide states that claims based on objective, measurable and numerical data must be proven through scientific tests, reports or documents in the context of advertising assessments.
The third principle is sectoral compliance. Health-related products are often subject to special legislation. A claim that may appear acceptable under general marketing language may still be unlawful under specific rules applicable to food supplements, cosmetics, medical devices, medicines or healthcare services. The Ministry of Trade expressly states that advertisements for health-sensitive categories must comply with their own sector-specific advertising and promotion rules.
The fourth principle is protection of vulnerable consumers. Advertisements must not exploit the lack of knowledge, experience, fear, illness, age or emotional vulnerability of consumers. Health advertising is particularly sensitive because consumers may be anxious, ill, desperate or seeking quick solutions.
The fifth principle is transparency. Sponsored health-related content must be clearly identifiable as advertising. Hidden advertising is prohibited in all communication media, and the Ministry of Trade states that all forms of hidden advertising through audio, written or visual communication tools are prohibited.
Misleading Health Claims
Misleading health claims are among the most frequently sanctioned advertising violations in Turkey. A health claim may be misleading if it gives the impression that a product or service can diagnose, treat, prevent or cure a disease without lawful basis. It may also be misleading if it exaggerates benefits, omits limitations, uses scientific language without proof, or presents ordinary effects as extraordinary health results.
For example, a food supplement advertised as “preventing flu,” a cosmetic cream promoted as “curing eczema,” a herbal product marketed as “treating cancer,” or a wellness service presented as “guaranteed pain relief” may create serious legal risk. Even statements such as “natural,” “herbal,” or “traditional” do not make a claim lawful. Natural origin does not automatically mean medical effectiveness, safety or legal permission to make health claims.
The Advertising Board’s enforcement practice shows that health claims are closely monitored. In its 369th meeting held on 14 May 2026, the Board specifically noted that question-and-answer areas in electronic marketplaces were frequently used by sellers for misleading health claims. The Board examined disease-related treatment expressions concerning certain vinegar products known as “Kadın sirkesi” or “Sultan sirkesi” and imposed administrative sanctions on nine firms.
This example is important because it shows that unlawful health claims may appear not only in formal advertisements but also in marketplace Q&A sections, product descriptions, comments, social media replies and informal consumer communication areas. Businesses should therefore monitor all consumer-facing content, not only official campaign banners.
Food Supplements and Health Claims
Food supplements are one of the highest-risk categories for health claims in Turkey. These products are often marketed with references to immunity, energy, digestion, sleep, stress, weight control, skin, hair, joints, memory or general well-being. However, food supplements are not medicines. They must not be presented as substitutes for medical treatment or normal nutrition.
The 2026 amendments to the Regulation on Commercial Advertising and Unfair Commercial Practices introduced specific rules for food supplement advertisements. According to the Ministry of Trade, food supplements may not be advertised in a way that creates the impression that they replace foods consumed as part of normal nutrition. The Ministry also stated that comparative advertising for these products may be possible except for matters falling within the scope of health claims.
This means that businesses cannot advertise food supplements as if they are essential alternatives to meals, balanced nutrition or medical care. For example, an advertisement suggesting that a supplement “replaces a healthy diet,” “provides everything your body needs,” or “makes medical treatment unnecessary” would be risky.
Food supplement advertisements should also avoid disease-related claims. Expressions such as “prevents infection,” “treats anemia,” “cures joint inflammation,” “protects against cancer,” or “eliminates anxiety” may be considered unlawful unless expressly permitted under applicable legislation and supported by legally acceptable evidence.
For safer compliance, food supplement advertising should focus on legally permitted statements, accurate product information, proper usage instructions and clear limitations. Claims should be reviewed before publication, especially on e-commerce platforms, social media and influencer campaigns.
Cosmetics Advertising and Health Claim Risks
Cosmetics are another important category. Skincare products, hair care products, anti-aging creams, sunscreens, serums, shampoos, beauty devices and similar products are frequently advertised with strong performance claims. However, cosmetics should not be promoted as medicines or medical treatments.
A cosmetic product may lawfully be advertised for beautifying, cleansing, protecting, perfuming or improving appearance within the limits of applicable rules. However, if the advertisement suggests disease treatment or physiological medical intervention, it may cross the legal boundary. For example, claims such as “treats psoriasis,” “cures acne,” “repairs skin disease,” “eliminates hair loss permanently,” or “removes scars completely” may create health claim risk.
Before-and-after images are also risky. If lighting, filters, makeup, angles, editing, AI-generated visuals or retouching exaggerate the effect, the advertisement may mislead consumers. A skincare advertisement using a skin-smoothing filter may create a false impression about the actual performance of the product. Similarly, a hair product advertisement may mislead if digital enhancement makes the hair appear thicker or shinier than the product can realistically achieve.
Testimonials in cosmetics advertising should also be carefully reviewed. A consumer or influencer may say “this cured my acne” or “this fixed my skin disease,” but such statements may still be treated as advertising claims if used by the brand. The advertiser cannot avoid responsibility by presenting unlawful health claims as user opinions.
Healthcare Services and Medical Advertising
Healthcare services are subject to stricter advertising sensitivity because consumers may make decisions affecting their health, body integrity and medical treatment. Clinics, doctors, hospitals, dental practices, aesthetic centers, hair transplant centers, physiotherapy centers and similar providers must be careful when using promotional language.
Advertisements for healthcare services should not mislead consumers, create unrealistic expectations, guarantee results or exploit patients’ vulnerability. Claims such as “guaranteed success,” “painless and risk-free surgery,” “permanent solution,” “best doctor,” “100% result,” or “no complications” may create legal and ethical risk.
The Ministry of Trade’s consumer information guide also states that testimonial advertisements may not include any image, statement or reference suggesting that doctors, dentists, veterinarians, pharmacists or health institutions make health claims regarding a product or service.
This rule is important because doctor-like endorsement is highly persuasive. Consumers may place special trust in healthcare professionals. Therefore, using medical titles, white coats, hospital visuals, expert references or professional imagery in a way that suggests unauthorized health endorsement can be legally problematic.
Healthcare providers should also be careful with patient stories and before-and-after visuals. Even if a real patient consents to the use of images, the advertisement must not create a misleading impression that the same result is guaranteed for all patients. Medical outcomes depend on individual conditions, risks, diagnosis, treatment plan and professional judgment.
Doctor, Pharmacist and Expert Endorsements
Doctor, pharmacist, dentist, veterinarian and health institution endorsements are closely regulated. Turkish advertising law recognizes that references to health professionals may strongly influence consumers. A consumer may believe that a product is medically safe, effective or necessary if a doctor-like figure appears to recommend it.
The Ministry of Trade’s consumer guide expressly states that testimonial advertisements may not include images, statements or references suggesting that doctors, dentists, veterinarians, pharmacists or health institutions make health claims about a product or service.
This restriction should be understood broadly. It is not only a direct sentence such as “Dr. X recommends this product” that may create risk. A white coat, stethoscope, clinic background, medical title, pharmacy setting, or expert-looking actor may also create a health endorsement impression. The risk increases if the product is a food supplement, cosmetic, herbal product, wellness device or any item not authorized as a medical treatment.
Academic titles must also be used carefully. The 2026 amendments introduced a rule preventing misleading or deceptive use of academic titles in commercial advertisements and announcements. This is highly relevant to health advertising because academic titles may create an impression of scientific authority. A title should not be used to imply medical proof or official approval where such proof or approval does not exist.
Scientific Claims and Clinical Evidence
Health advertising often uses scientific language. Expressions such as “clinically proven,” “scientifically tested,” “laboratory approved,” “doctor approved,” “research-based,” “contains active ingredients,” “proven effect,” or “supported by studies” may increase consumer trust. However, such claims must be used only when they can be substantiated.
A scientific claim should be specific, accurate and supported by reliable evidence. A vague reference to “studies” is not enough. The advertiser should be able to show what study was conducted, which product or ingredient was tested, what the methodology was, what the result showed, whether the study is relevant to the advertised claim and whether the evidence applies to the product as sold.
For example, if an ingredient has been studied in a laboratory, this does not automatically prove that the finished consumer product produces the same effect in normal use. If a study was conducted on adults, the advertiser should not imply the same result for children unless supported. If a claim depends on a certain dosage or usage period, this should be made clear.
Scientific graphics, lab visuals and technical terminology may also mislead consumers if they create an impression of proof without adequate basis. Businesses should avoid using science-themed design merely as a persuasion tool.
Health Claims in E-Commerce
E-commerce platforms are increasingly important in health-related advertising. Product pages, seller descriptions, search tags, marketplace Q&A fields, consumer reviews, sponsored rankings and product comparison tools can all include health-related statements.
The Advertising Board’s 2026 enforcement concerning vinegar products shows that sellers may face sanctions for misleading health claims made in marketplace question-and-answer areas. This means that businesses must monitor not only official product descriptions but also Q&A sections, automated replies, marketplace messages, seller comments and user-facing explanations.
E-commerce platforms should also avoid allowing sellers to use disease names or treatment terms in titles and tags unless legally permitted. Terms such as “diabetes,” “cancer,” “eczema,” “anxiety,” “migraine,” “arthritis,” “infection,” or “treatment” may attract consumers searching for medical solutions and may create unlawful health claim risk.
Product reviews can also be problematic. If a consumer writes “this cured my disease” and the seller highlights, pins, promotes or uses the review in advertising, the statement may become part of the advertisement. Platforms and sellers should establish review moderation policies that prevent unlawful health claims from being used as promotional material.
Health Claims in Influencer Marketing
Influencer marketing is highly influential in health, beauty, wellness and food supplement sectors. Influencers often share personal stories, daily routines, product recommendations, discount codes and before-and-after experiences. However, health claims made by influencers are subject to advertising law when the content has a commercial purpose.
If an influencer receives payment, free products, discounts, commission, event participation or any other benefit, the commercial nature of the content must be clearly disclosed. Hidden advertising is prohibited in all communication media.
Disclosure alone is not enough. The influencer must also avoid unlawful health claims. For example, an influencer should not say “this supplement prevented me from getting sick,” “this cream cured my skin condition,” “this detox tea cleansed my liver,” or “this procedure is risk-free and guaranteed” unless the claim is legally permitted and supported. A brand cannot lawfully use influencers to make claims that the brand itself could not make.
Influencer agreements should include detailed clauses on prohibited health claims, disclosure obligations, content approval, product experience, use of filters, before-and-after images, scientific references, correction obligations and immediate takedown. Brands should also provide influencers with approved wording and monitor published content.
Weight Loss, Detox and Wellness Claims
Weight loss, detox and wellness advertising are particularly risky. Consumers seeking weight loss or health improvement may be emotionally vulnerable and highly responsive to quick-solution claims. Turkish advertising law requires careful review of claims that suggest rapid, effortless, guaranteed or medically significant results.
Risky claims include:
“Lose 10 kilograms in one month.”
“Burns fat while you sleep.”
“Detoxifies your body.”
“Cleanses your liver.”
“Stops appetite naturally.”
“Permanent slimming.”
“No diet or exercise needed.”
“Guaranteed body transformation.”
Such statements may mislead consumers if they are not scientifically supported, if they exaggerate results or if they imply medical effects. Before-and-after visuals may also be misleading if they are not representative, if the time period is unclear or if other factors such as diet, exercise, medical treatment or editing are not disclosed.
Wellness advertising should avoid disease treatment implications. Terms like “balance,” “cleanse,” “reset,” and “boost” may appear softer than medical terms, but they can still create a health claim depending on the context.
Health Claims and Children
Children are a vulnerable consumer group. Health-related advertising directed at children or parents requires special care. Products such as vitamins, supplements, foods, educational products, hygiene products and wellness services may be marketed with claims about growth, immunity, intelligence, concentration, appetite, sleep or physical development.
Advertisements should not exploit parental anxiety. Claims such as “essential for your child’s intelligence,” “protects your child from illness,” or “children who use this perform better” may be misleading unless legally permitted and supported by strong evidence. Even where a claim is supported, it should not create fear, guilt or pressure.
The 2026 amendments also prohibit targeted advertising directed at children through profiling based on personal data. This rule is relevant where health-related products are advertised through apps, games, video platforms or social media systems using behavioral data.
Health Claims and AI-Generated Advertising
AI-generated advertisements may increase health claim risks. Brands can now create synthetic doctors, virtual patients, AI-generated testimonials, deepfake-like endorsements, before-and-after visuals and automated health-related copy. These tools may mislead consumers if they create false medical credibility or fake personal experience.
The 2026 amendments introduced specific rules on AI-generated advertisements. Where advertisements use AI-generated digital characters that cannot be distinguished from real humans, this must be clearly, understandably and distinguishably disclosed. The amendments also prohibit advertisements using the AI-generated digital copy of a real person in a way that creates the impression that the person personally experienced or recommended a product or service.
In health advertising, this rule is particularly important. A virtual doctor, synthetic patient or digital influencer should not create the impression of real medical experience or recommendation. AI-generated before-and-after results should not exaggerate product performance or treatment outcomes.
Advertising Board Enforcement and Sanctions
The Advertising Board actively supervises misleading health claims. In its 342nd meeting, the Board emphasized that advertisements concerning food supplements, foods, cosmetics and healthcare services are carefully monitored, especially because they directly concern consumer health. The Board found 157 out of 185 reviewed files unlawful in that meeting and imposed sanctions in 47 health-related files.
The Board’s 369th meeting also shows continued enforcement. In May 2026, the Board reviewed 156 files, found 146 unlawful, imposed approximately 23 million TL in administrative fines and decided access blocking for 17 advertisements. The same announcement specifically noted administrative sanctions for misleading health claims in electronic marketplace Q&A sections.
Administrative fines can be significant. For 2026, the Ministry of Trade announced that administrative fines under Law No. 6502 were increased by 25.49% as of 1 January 2026. The Ministry explained that 2026 fines for misleading advertisements and unfair commercial practices may vary depending on the medium, nature of violation, benefit obtained, harm caused, fault and economic situation of the violator.
Sanctions may include suspension, correction, administrative fines and, in online cases, access blocking. The Ministry of Trade’s consumer information guide states that the Advertising Board may impose suspension, correction, administrative fines, temporary suspension and access blocking measures for unlawful advertisements.
Civil, Administrative and Reputational Risks
Health claim violations may create multiple layers of risk. First, there is administrative risk before the Advertising Board. Second, sector-specific authorities may take action depending on the product or service category. Third, consumers may file complaints or claims if they purchased a product based on misleading health representations. Fourth, competitors may raise unfair competition objections if unlawful health claims distort the market.
Reputational risk may be especially serious. Consumers react strongly to misleading health-related promotions because such advertisements may affect bodily integrity, illness, treatment decisions and family health. A brand accused of exploiting health concerns may suffer long-term trust damage.
Businesses should therefore treat health advertising as a high-risk compliance area. Marketing speed should never override legal review.
Practical Compliance Checklist for Health Claims
Before publishing any advertisement containing health-related language, businesses should apply the following checklist:
Identify whether the advertisement contains an express or implied health claim.
Determine the product category: food supplement, cosmetic, medical device, healthcare service, medicine, wellness product, biocidal product or other category.
Check sector-specific rules applicable to that category.
Avoid disease diagnosis, treatment, prevention or cure claims unless expressly permitted.
Do not present food supplements as substitutes for normal nutrition or medical treatment.
Do not present cosmetics as medicines.
Do not use doctor, pharmacist, dentist, veterinarian or health institution references in a way that suggests health endorsement.
Verify all scientific and clinical claims with reliable evidence.
Avoid guaranteed-result statements.
Review before-and-after visuals, filters, editing and AI-generated images.
Monitor e-commerce Q&A sections, comments and reviews.
Ensure influencer disclosures are clear and health claims are legally approved.
Avoid exploiting children, patients, elderly consumers or vulnerable groups.
Preserve all substantiation documents, approvals, screenshots and campaign records.
This checklist should be applied before publication. Later correction may reduce harm but may not eliminate liability.
Best Practices for Businesses
Businesses should create internal health claim policies. Marketing teams should not independently create health-related slogans without legal and technical review. Product managers, regulatory teams, legal counsel and advertising agencies should work together.
Approved claim libraries may be useful. A business can prepare pre-approved wording for each product category and prohibit high-risk expressions such as “cure,” “treat,” “prevent disease,” “guaranteed,” “doctor approved,” “risk-free,” “permanent,” and “medical solution” unless legally justified.
For e-commerce, businesses should monitor seller panels, marketplace Q&A sections, reviews and product tags. For influencer marketing, brands should provide written instructions and require content approval before publication. For AI-generated content, brands should review every health-related statement and visual before use.
Conclusion
Health claims in advertising in Turkey are subject to strict legal restrictions because they directly affect consumer health, public interest and market trust. A health-related claim may be commercially attractive, but it may also create serious legal risk if it is misleading, unsupported, unauthorized or presented in a way that exploits consumer vulnerability.
Turkish advertising law requires health-related advertisements to be truthful, substantiated, transparent and compliant with sector-specific rules. Advertisements for medicines, medical devices, health services, foods, food supplements, cosmetics and similar products must comply not only with general advertising law but also with their own regulatory frameworks.
Enforcement practice confirms the importance of compliance. The Advertising Board has repeatedly examined health-related advertisements, including food supplements, cosmetics, health services and misleading health claims in e-commerce environments. In 2024, health-related files were a main agenda item of the Board’s 342nd meeting, and in 2026 the Board sanctioned misleading health claims made through marketplace Q&A areas.
For businesses operating in Turkey or targeting Turkish consumers, the safest approach is clear: do not make health claims unless they are legally permitted, scientifically supported and carefully worded. Health advertising should inform consumers, not exploit fear or hope. It should support lawful consumer choice, not create false expectations.
A compliant health advertising strategy protects consumers, reduces regulatory risk and strengthens brand credibility. In the Turkish market, responsible health communication is not only a legal requirement; it is also an essential part of long-term consumer trust.
No Responses