Türkiye’s new rules for refurbished products strengthen consumer protection and oversight

The Regulation establishes a comprehensive legal framework governing the refurbishment and resale of designated used products in Türkiye. By repealing and replacing the existing Regulation on the Sale of Refurbished Products, the new framework introduces broader compliance obligations for market participants while expanding the range of products eligible for refurbishment and enhancing consumer protection requirements.

Purpose and scope

The Regulation sets out the rules and procedures applicable to the refurbishment and resale of designated used products. The Regulation applies to refurbishment centres, authorised sellers, on-site refurbishment points and other entities participating in the refurbishment ecosystem.

The list of products eligible for refurbishment has been expanded and now includes mobile phones, tablets, smart watches, computers, game consoles, modems and televisions.

In line with the Ministry’s announcement dated 30 April 2026, the Regulation expands the range of eligible refurbished products and introduces enhanced consumer protection, transparency and oversight mechanisms in an effort to strengthen consumer confidence in refurbished products while supporting the growth of Türkiye’s circular economy and the reuse of electronic devices.

Fundamental obligations

Mandatory use of YÜBİS

All refurbishment operations must be conducted through the Refurbished Product Information System (YÜBİS), an electronic platform established by the Ministry. An electronic certificate must be generated through the system and provided to consumers, and all refurbishment centres, authorised sellers and on-site refurbishment points must also be registered with YÜBİS.

In addition, refurbishment centres are required to upload Turkish user manuals for refurbished products to YÜBİS. Upon request, consumers must be provided with manuals in hard copy or through a durable data storage medium.

Refurbishment process 

For products containing electronic identity information, the Regulation requires the following: 

• the device is registered on the White List available through e-Government; 
• the device has at least one year of historical usage traffic; 
• the device is activated on a mobile operator network through a line declared in YÜBİS; and 
• the device completes at least one successful call. 

These criteria are verified through YÜBİS using records obtained from the Information and Communication Technologies Authority (BTK), and non-compliant devices cannot be refurbished.

The valuation of a used product must be completed within three business days of delivery, and the consumer’s acceptance must be obtained in writing or through a durable data storage medium. The agreed payment and any promised benefits must be provided within three business days of the consumer’s approval, subject to a limited extension with prior consent.  A refurbished product may only undergo a further refurbishment after at least 30 days have elapsed from the previous refurbishment date.

Enhanced transparency requirements

Refurbished products must be clearly marketed and sold as “refurbished”, and information regarding the relevant refurbishment centre must be displayed on packaging, labels, advertisements and promotional materials. 

Where different prices are applied within the same refurbished product category, consumers must be clearly informed about the physical or technical characteristics that justify the price differences before consumers assume any payment obligation.

Stricter requirements for refurbishment centres

The Regulation significantly strengthens the conditions for obtaining a refurbishment authorisation certificate.

The following conditions must be satisfied in order to obtain a refurbishment authorisation certificate:

• The applicant must hold a competency certificate obtained in accordance with the requirements set out in the regulations or standards designated by the Ministry.
• The applicant must be incorporated as a capital company.
• Individuals authorised to represent the company must: 
  • be 18 years or older.
  • not be bankrupt or, if previously declared bankrupt, have had their reputation restored; and
  • meet strict integrity and eligibility requirements, including the absence of convictions for a broad range of serious offences and any judicial prohibition on conducting commercial or professional activities.
• The company must have paid-in capital of not less than TRY 100 million.
• The applicant must satisfy any other requirements to be announced by the Ministry.

The minimum capital threshold was previously TRY 30 million and has now been increased to TRY 100 million.

Authorisation certificates are issued separately for each refurbishment centre, are non-transferable and remain valid for five years.

New consumer rights

One of the most significant changes is the extension of the 14-day withdrawal right to refurbished products purchased through non-distance sales channels, such as physical stores. Consumers may withdraw without providing any reason and without incurring penalties. The withdrawal period begins on delivery (or may be exercised between conclusion of the contract and delivery), and all refunds must be made within 14 days using the consumer’s original payment method. The consumer is not liable for any changes or deterioration resulting from ordinary use during the withdrawal period.

Warranty and after-sales obligations

The Regulation introduces specific warranty and after-sales service obligations for refurbished products.

The warranty period starts upon delivery and must be at least one year. Where consumers choose free repair or replacement with an equivalent refurbished product, this must be fulfilled within 20 business days of the date the product is delivered to the authorised seller or refurbishment centre. Consumers may not be charged for any costs (including shipping and transportation) incurred in connection with warranty claims. 

Record-keeping and data protection compliance

Information and documentation relating to transactions carried out under the Regulation must be retained for five years. Processing of personal data in connection with refurbishment activities must also comply with the Turkish Personal Data Protection Law No. 6698 and related secondary legislation.

Responsibility of market participants

The Regulation establishes a liability regime within the refurbishment ecosystem. Refurbishment centres are responsible for the activities of authorised sellers and on-site refurbishment points operating under their authorisation. Authorised sellers are jointly and severally liable with refurbishment centres for consumer rights arising under the Regulation. This joint, several liability extends to the on-site refurbishment point for the provision of maintenance and repair services throughout the warranty period, including where the refurbishment centre or authorised seller ceases commercial activity.

Enforcement and sanctions

The Ministry has established a dedicated Commission authorised to issue warnings, suspend or revoke refurbishment authorisation certificates. Where non-compliance continues despite a written warning, certificates may be cancelled. Changes affecting eligibility conditions must be notified to the Ministry within 30 days. Where conditions are no longer met, the Commission grants a period for rectification and can suspend the certificate during this period to protect consumers. If deficiencies are not remedied, or are non-remediable, the certificate is revoked. A centre whose certificate is revoked can not obtain a new one for one year.

Transition period and entry into force

The Regulation will enter into force on 1 August 2026.

Companies holding a refurbishment authorisation certificate as of that date may continue operating under their existing certificates without obtaining a new authorisation certificate, provided that they submit documentation by 1 September 2026 as evidence that they hold a competency certificate obtained according to the requirements set out in the regulations or Ministry standards, are incorporated as a capital company, and that the individuals authorised to represent the company satisfy the conditions set out in the Regulation. Documentation of compliance with the minimum paid-in capital requirement of TRY 100 million and any other Ministry requirements must be submitted by 31 December 2026. If these requirements are met within the prescribed deadlines, existing refurbishment centres may continue operating under their current refurbishment authorisation certificates for the remainder of their validity period without obtaining a new authorisation certificate. 

Conclusion

The Regulation reflects the Ministry’s objective of building a more transparent, reliable and consumer-friendly refurbished products ecosystem in Türkiye. By expanding the products categories, strengthening consumer rights, imposing higher financial and operational standards and introducing greater traceability, the new framework aims to increase consumer confidence while supporting the growth of the circular economy and the reuse of electronic devices. Market participants involved in refurbishment, trade-in, buy-back and resale activities should take advantage of the transition period to ensure compliance with the enhanced requirements and prepare for a more closely regulated market from 1 August 2026.

For more information on the Regulation and its potential implications, contact the experts who contributed to this article: alican.babalioglu@ybk-av.com, melis.celik@ybk-av.com, and ezgi.bahar@ybk-av.com.