OBLIGATIONS OF COMPANIES RELATED TO RETAIL SALES

Obligations under Turkish consumer law cover a range of requirements that begin prior to the sale of a product, continue at the time of sale, and extend throughout its period of use. These include pre-sale obligations such as price tags and user guides, contractual requirements at the time of sale such as warranty certificates, as well as after-sale obligations including support, maintenance, repair, and returns. Such obligations constitute not merely a matter of customer satisfaction, but also an essential element of consumer protection, brand reputation, client loyalty, and legal compliance.

The proper and legal performance of these obligations is of critical importance, both for safeguarding consumer rights and for preserving the long-term sustainability of brand reputation and customer trust.

This Newsletter examines the legal obligations of companies under Turkish law with respect to price tags, introductory and user guides, warranty certificates, and after-sales services.

1. Price Tag Regulation

Pursuant to Article 54 of Consumer Protection Law No. 6502, goods offered for retail sales, or their packaging or containers, must bear price tags. Such price tags (i) shall be clearly visible and legible, (ii) shall reveal the unit price and the sales price of the related good, in a manner to comprise all taxes payable by the consumer and (iii) shall be prepared in a manner to disclose the country of manufacture and the distinctive features of the related good.

On the tags and the lists, the below information shall be indicated in Turkish as per Article 5 of the Price Tag Regulation (in Turkish, “Fiyat Etiketi Yönetmeliği”) with the heading “The Obligation to Place Labels on Products”:

1. Country of manufacture of the product,
2. distinctive features of the good,
3. sales price of the goods in a manner comprising all taxes (e.g. VAT),
4. unit price of the good,
5. date of implementation of the sales price and the unit price,
6. (if any) figure, logo or sign determined and announced by the Ministry of Trade for the products having been manufactured in Türkiye,
7.  If there is a deposit fee for the delivery and return of the packaging separately from the sales price of the packaged goods, the amount of such fee.

Kindly note that the country of manufacture of the imported goods shall be written on the price tags in the Turkish language in accordance with Article 5 (3) of the Regulation.

Except for the price lists of package tours and education services to be performed abroad and transportation and accommodation services for abroad, it is obligatory to write the sales prices on the labels and lists as ‘Turkish Lira’, ‘TL‘ or its symbol.

Finally, kindly note that (i) in case of difference between the sales price of the product and the cashpoint price, the price in favor of the consumer shall apply, (ii) the sales price of the goods or services subject to discount, shall be indicated along with the price prior to the discount on the tariffs and price lists and tags and (iii) the discounted sales price is indicated together and using the same font size with the pre-discount sales price.

Also, according to Article 5/D of the Communiqué Amending the Communiqué on Conformity Inspection of Certain Consumer Products (in Turkish, “Bazı Tüketici Ürünlerinde Uygunluk Denetimi Tebliği’nde Değişiklik Yapılmasına Dair Tebliğ”);

• For consumer products containing animal-derived components, the specific animal from which the component is obtained must be indicated on the product label, packaging, or accompanying documentation.
• In distance sales, this information must also be presented clearly to the consumer together with the product specifications.

The information must be provided in Turkish, in a visible, legible, and non-misleading manner.

2. Introductory And User Guide

The Regulation on the Introductory and User Guides (in Turkish, “Tanıtma ve Kullanma Kılavuzu Yönetmeliği”) sets forth the terms regulating the guides provided to the customers along with the products regarding the introduction, use, installation, maintenance and repair instructions of the relevant product. Introductory and user guides might be written or added on the packing of the product according to the features or presentation of the product.

The Regulation sets forth the products for which it is not mandatory to provide a user manual, as follows:

• All types of metal, PVC, polyethylene and similar plastic pipes and fittings, as well as bolts, clamps, screws, studs, pins, and similar fastening elements,
• Paper, pencils, erasers, and similar stationery materials,
• Shovels, spades, pickaxes, rakes, wheelbarrows, and similar agricultural tools,
• Pliers, screwdrivers, hammers, chisels, saws, scissors, and similar mechanical hand tools,
• Handkerchiefs, belts, suspenders, buttons, zippers, and similar clothing accessories,
• Construction materials such as bricks, tiles, briquettes, and bulk-sold materials such as cement, lime, sand, gravel, coal, and similar minerals and products,
• Kitchen utensils such as forks, spoons, ladles, knives, plates, glasses, and similar items, as well as household items such as scissors, vases,
• Handicrafts, jewelry, and similar artistic products,
• Mechanical measuring tools such as measuring tapes, calipers, and squares,
• Spare parts replaced by service stations.

All products offered for consumer use other than those listed above are obliged to be sold with an introduction and user guideissued in Turkish and in a clear, simple and understandable manner, including but not limited to the following:

• All clothing products, excluding accessories such as handkerchiefs, belts, trouser suspenders and similar apparel accessories.
• Leather bags, small leather goods
• Watches
• Shoes (footwear in general)
• Cosmetic products

The introductory and user guide must include, inter alia, rules on use, installation, maintenance and simple repair; possible usage errors; maintenance, repair or cleaning to be carried out by the customer; and the expected lifetime of the product.

3. Warranty Certificate

As the Regulation on Warranty Certificate (in Turkish, “Garanti Belgesi Yönetmeliği”), manufacturers and importers shall issue a warranty certificate for the products imported or put on market for the consumers in compliance with the legal requirements as to the content thereof.

Unless otherwise determined by the Ministry of Trade, due to the particularities of the products, the warranty period shall begin as from the delivery of the product and cannot be less than 2 (two) years. In case of repair, the time elapsed during the repair shall be added to the warranty period.

As listed in the annex of the said Regulation, for instance, sunglasses and spectacle frames, watches, wooden and metal furniture fall under the products to be sold along with a warranty certificate.

4. After-Sales Services

As set forth in the Regulation on After-Sales Services (in Turkish, “Satış Sonrası Hizmetler Yönetmeliği”), manufacturers and importers are required to obtain an after-sales service qualification certificate approved by Ministry of Trade for the products in the annexed list of the said Regulation. After-sales service qualification certificate shall be valid for two (2) years and must be renewed before its validity period expires.

For instance, watches are subject to the aftersales service requirements foreseen as per the Regulation on the After Sales Services and the manufacturers or importers thereof shall obtain an Aftersales Services Competency Certificate (in Turkish “Satış Sonrası Hizmetleri Yeterlilik Belgesi”) certified by the Ministry of Customs and Trade for such products as per the Article 6 of the said Regulation.

As per the annex of the Regulation on the After Sales Services; the lifetime of watches is determined as five (5) years, numbers of services are determined as one (1) and the maximum repair time is set forth as twenty (20) business days.

Our Law Firm remains at your disposal for any further clarifications you may need.

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