Medical devices · Türkiye İlaç ve Tıbbî Cihaz Kurumu

Türkiye deleted UK certificates

In February 2020 the regulator cut the validity of every EC certificate issued by a UK notified body to 31 December 2020 in its national system, with no extension. UKCA appears nowhere in Turkish device law. And yet Türkiye may be the best place in the world for a UK manufacturer to obtain a CE certificate.

UKCA certificate or a UK Approved Body no standing in the regulation Notified body established in Türkiye 1984 · 2292 · 2764 CE certificate under EU MDR Turkish market EU / EEA market
The customs union is why the same certificate opens both doors — and why a body in Ankara can issue it when a body in London cannot.
0mentions of UKCA in either Turkish device regulation
3notified bodies in Türkiye carrying EU MDR numbers
₺335per product registration, published in the annual tariff
EU or TRwhere your authorised representative is allowed to sit
Who this applies to

The one market here that does not demand a local holder

Saudi Arabia requires a Saudi-licensed representative. The UAE requires a UAE-licensed establishment. Egypt requires one of three Egyptian entities. Türkiye does not. Its Medical Device Regulation defines the authorised representative — yetkili temsilci — as a person established in Türkiye or in an EU member state, and TİTCK has confirmed that EU-established representatives carry the same rights and obligations as Turkish ones.

That is a direct consequence of the customs union, and it is the single biggest structural difference between this market and the other three. If you already hold an EU authorised representative for your MDR file, you may not need a second one.

  • Authorised representative

    Appointed in writing; jointly and severally liable with you for defective devices

    Türkiye or the EU
  • Importer

    Defined as a person placing a device from a third country on the Turkish market

    Türkiye only
  • Sales centre

    Needs an authorisation certificate from the provincial health directorate before it may sell

    Türkiye only
  • Manufacturer

    Registers for a single registration number alongside the representative and importer

    Anywhere

What this does not remove. The importer must still be established in Türkiye, and nobody may sell your device unless they hold a sales centre authorisation and the device is registered in the national system. The regulation makes that explicit: an authorised sales centre may not sell a device that is not registered. So you still need Turkish partners — you just do not need one of them to hold your regulatory file.

The question everyone asks first

Does your CE, UKCA or FDA approval help?

CE is the only answer. UKCA is not merely unrecognised — it was actively removed.

We searched the consolidated texts of both the Medical Device Regulation and the IVD Regulation. UKCA appears zero times. So does "Birleşik Krallık". So does "İngiltere". CE marking appears throughout, and Article 20 requires it on every device that is not custom-made or investigational.

More pointedly: TİTCK announcement 2020/KK-3, issued 13 February 2020, ruled that EC certificates issued by BSI Assurance UK (0086), Lloyd's Register Quality Assurance (0088), SGS United Kingdom (0120) and UL International UK (0843) would have their validity truncated to 31 December 2020 in the national system, after which the system would drop them and no extension would be granted. That is not an oversight about Brexit. It is a decision taken about it.

The only TİTCK document that mentions UKCA at all points the other way: a 2022 announcement telling Turkish manufacturers that they need a UK Responsible Person and MHRA registration to sell into Great Britain.

FDA clearance does not help either. Türkiye transposed EU MDR and IVDR wholesale. There is no reference-country list, no reliance route and no abridged assessment for a 510(k) or a PMA. The only currency is a CE certificate from a body the EU recognises.

The part that is actually good news

Three notified bodies in Türkiye can issue your CE certificate

Because Türkiye is inside the customs union for industrial goods, conformity assessment bodies designated there are treated as equivalent to those designated in EU member states, and their certificates are mutually recognised. In the European Commission's own database, three bodies established in Türkiye carry EU MDR numbers.

NB numberBodyLegislation
1984Kiwa Belgelendirme Hizmetleri A.Ş.EU MDR 2017/745
2292UDEM Uluslararası Belgelendirme Denetim Eğitim MerkeziEU MDR 2017/745
2764Notice Belgelendirme, Muayene ve Denetim Hizmetleri A.Ş.EU MDR 2017/745

Read from the European Commission's EUDAMED notified-bodies module in September 2026, which returned 53 bodies in total. Türkiye is the only non-EU and non-EEA country among them. Two corrections to assumptions we have seen in the trade press: TSE does not appear in that list at all, and SZUTEST appears only as a German entity, not a Türkiye-designated one.

Two limits, and a caveat about our own source. All three are designated under MDR only — there is no IVDR notified body in Türkiye, so an in-vitro diagnostic cannot take this route. And we read the designations from EUDAMED rather than from NANDO, the formal designation register, which has migrated to the Commission's Single Market Compliance Space and did not respond when we tried it. EUDAMED is an official Commission database, but it is not the designation register, so we treat the absence of TSE as provisional and re-confirm any body before a client instructs it.

The route

Registration is two filings, then a third party

Türkiye runs everything through ÜTS, the national product tracking system. Certificates are registered first; products second; and neither can be sold until somebody holding a sales centre authorisation does the selling.

BELGE KAYIT Certificate registration EC certificate + DoC · ₺335 each ÜRÜN KAYIT Product registration ₺335 per application SATIŞ MERKEZİ Authorised to sell provincial certificate · ₺3,617 The CE certificate needs an apostille or Turkish consular legalisation, no notarised copy The representative’s mandate does not original plus a sworn Turkish translation An authorised sales centre may not sell a device that is not registered in ÜTS.
The asymmetry in the middle row is the kind of detail that costs a fortnight: one document must be apostilled and the other must expressly not be.
  1. 01

    Get, or confirm, a CE certificate

    Under the Turkish regulation this is not optional and there is no substitute. Class I devices that are not sterile, not measuring and not reusable surgical instruments self-declare; everything from Class Is upwards needs a notified body. If your certificate came from a UK body, it has had no standing here since the end of 2020.

    You, with us
  2. 02

    Appoint the authorised representative

    Mandatory because you are established neither in Türkiye nor in the EU. The appointment takes effect when a mandate is issued and the representative accepts it in writing, and it must cover at least all devices in the same generic device group.

    Us, with you
  3. 03

    Register the economic operators

    Manufacturer, authorised representative and importer each register for a single registration number before the device is placed on the market. Data must be updated within one week of any change, confirmed within a year and every two years after that. Distributors are outside this obligation and sit under the sales regime instead.

    Us
  4. 04

    Register the certificates, then the products

    Two separate filings in ÜTS, priced separately. The Turkish importer performs the document registration and uploads the mandate between you and your representative, with a sworn Turkish translation.

    Importer, managed by us
  5. 05

    Load the Turkish instructions for use

    The current Turkish user manual is uploaded to ÜTS in full, with its update date recorded. The language obligation comes from the product safety law by cross-reference rather than from the device regulation itself, but the system enforces it directly.

    You, with us
  6. 06

    Make sure whoever sells is authorised

    Your distributor needs a sales centre authorisation from the provincial health directorate. The directorate reviews documents within fifteen working days and inspects the premises within forty-five working days of the application.

    Shared — we run the calendar
Time and money

Türkiye publishes its prices and not its clocks

This is the exact inverse of Egypt, where the regulator publishes review periods in working days and not a single fee. TİTCK publishes a full annual tariff in Turkish lira, reissued during the year, and sets no published evaluation period for registration at all.

Item2026 fee, ₺
Product registration application, per application335
Certificate registration, per document — EC certificate, declaration of conformity335
Sales centre authorisation certificate3,617
Free sale certificate, 1–50 products3,349
Free sale certificate, 51–250 products6,634
Free sale certificate, 251 products and above9,918
Certificate extension application under EU 2023/6074,637
Device and class determination, per device51,527
Placing-on-market notification permission12,881
Economic operator registration in ÜTSnot charged

TİTCK 2026 price tariff, version dated 23 March 2026. We searched all 332 rows for an ÜTS or economic-operator fee and found none, and there is no annual maintenance fee for a device registration. Fees are set by a published methodology and re-set at least annually; they are not, on any TİTCK publication we found, formally indexed to the revaluation rate. Amounts are paid to TİTCK and billed to you at cost. Get the current figures for your device →

On timing, the regulator says nothing — and we will not invent it.

There is no occurrence of "within … days" anywhere in the Medical Device Regulation as a limit on the authority. The deadlines that do exist run against you: payment for a free sale certificate within ten days or the application cancels itself, and an importer's obligation to act within two weeks of placing a device on the market. The only published authority-side periods we found are in the sales regime — fifteen working days to review documents and forty-five to inspect.

The trade question

Is UKCA recognition coming? On the published record, no

The UK and Türkiye have a free trade agreement in force since January 2021, and they amended it — the technical barriers to trade chapter was replaced by an exchange of letters dated 7 May 2025, laid before Parliament that September. Its two sectoral annexes cover chemicals and motor vehicles. There is no medical devices annex.

Negotiations for an enhanced agreement have run five rounds through June 2026, with eleven chapters reported closed. The published round summaries name digital trade, telecommunications, investment, legal services, goods market access, sanitary and phytosanitary measures, intellectual property, procurement and sustainability. Conformity assessment, mutual recognition and medical devices are not among them.

What we would tell a board. Do not sequence Türkiye on the expectation that UKCA becomes acceptable. Nothing published supports it, the one amendment made so far chose other sectors, and the practical alternative — a CE certificate from a notified body in Türkiye or the EU — is available today and opens the European market at the same time. We also could not confirm that the 2025 exchange of letters has entered into force, so we do not describe it as in force.

Honest gaps

What we could not confirm

  • NANDO itself

    The Commission's formal designation register has moved to the Single Market Compliance Space and did not respond. The three Turkish notified bodies are confirmed from EUDAMED, an official Commission database but not the designation register.

  • Whether devices sit on the procurement list

    Turkish public procurement law gives a price advantage of up to fifteen per cent for domestically produced goods, mandatory at fifteen per cent for goods on a designated medium and high technology list. We could not open the current list, so we cannot tell you whether your category is on it.

  • Whether the 2025 TBT amendment is in force

    Signed 7 May 2025 and laid before Parliament, but we found no entry-into-force notice. An earlier version of the same instrument was withdrawn.

  • Whether one entity may be both representative and importer

    The regulation defines them as distinct roles without prohibiting combination, and requires only the importer to be Turkish. We found no guidance either permitting or forbidding it.

  • Whether ÜTS registration conditions reimbursement

    The social security institution's own page does not state it as a precondition and routes applications through its own portal. The health implementation communiqué is where any such rule would sit and we have not read it.

Everything on this page comes from Turkish-language sources: there is no official English text of either device regulation, of the tariff, or of the ÜTS guidance. Where we quote a requirement, we hold the Turkish original.

Our role

What we do here, and what we do not

We do

  • Establish whether your CE route is intact, and price the alternative through a Turkish or EU notified body
  • Decide where the authorised representative should sit — Türkiye or the EU — and what that does to your other markets
  • Run the two ÜTS filings and the mandate registration with the Turkish importer
  • Check the sales centre authorisation of whoever proposes to sell for you, before you sign with them
  • Hold the calendar: operator data updated within a week of a change, confirmed every two years

We do not

  • Act as your importer or sales centre — both must be established in Türkiye
  • Issue or broker a CE certificate. We are not a notified body and take no commission from one
  • Tell you UKCA might be accepted. It appears zero times in the law and UK certificates were dropped in 2020
  • Promise a registration date. The regulator publishes no evaluation period at all
  • Quote last year's tariff. It is reissued in-year and we check it before every invoice
Before we start

What we will ask you for

  • Device description, intended purpose and variants in scope
  • Your class under EU MDR Annex VIII, and how you reached it
  • Your CE certificate — and critically, which notified body issued it and whether that body is UK-established
  • EU declaration of conformity
  • ISO 13485 certificate
  • Whether you already hold an EU authorised representative, and the mandate
  • Turkish instructions for use, or the source text to translate
  • Your intended Turkish importer, and whether it holds a sales centre authorisation
  • Whether your device is an in-vitro diagnostic — that closes the Turkish notified body route
  • Whether you sell into public tenders in Türkiye

The first question is the one that decides the project. If your CE certificate was issued by a UK notified body, you do not have a Turkish registration problem; you have a certification problem, and it needs solving before anything else on this page is worth doing.

Moving parts

What changed, and what did not

  1. Apr 2023The EU's transition extension for MDR certificates was transposed into the Turkish regulation, so the European timetable and the Turkish one stay aligned
  2. Aug 2024The only amendment to either device regulation since 2023: notified body re-assessment every five years, unique identifiers for contact lenses, the staged EUDAMED roll-out, and a new duty to notify interruption or discontinuation of supply
  3. May 2026New ÜTS registration guidance at version 4.0, running to 317 pages, which the regulator states prevails over its parameter cards and announcements
  4. Jul 2026The sales and advertising regulation amended again, qualifying the exemption from sales centre authorisation for internet sales of certain devices
  5. UnchangedNothing has moved on UK conformity assessment since February 2020. Zero mentions in the law, no reference route, and no medical devices annex in the one trade amendment made so far

The other half of this market

Do you also make medicines?

The answer inverts. On the device side the UKCA mark is not recognised at all. On the medicines side Türkiye and the MHRA are both PIC/S participants, so the MHRA's inspection findings count — and the binding constraint becomes a pricing euro fixed by decree at sixty-five per cent of last year's average market rate.

The medicines page for Türkiye →

The certificate problem comes first

If your CE certificate is intact, Türkiye is a cheap and mechanical registration. If it is not, this is a certification project wearing a market-access costume — and we would rather tell you that on the first call.

Or reach us directly — mail@bcabusiness.co.uk · +44 7342 901002 · WhatsApp

Checked against TİTCK, the Resmî Gazete
and EU databases · 11 September 2026

Sources

  1. Tıbbi Cihaz Yönetmeliği — Resmî Gazete 2 June 2021, no. 31499 mükerrer, transposing EU MDR 2017/745. Amended 29 July 2022 (31907), 2 April 2023 (32151) and 17 August 2024 (32635). Articles cited: 11 authorised representative, 20 CE marking, 31 registration of economic operators, 34 the national product tracking system, 51 classification, 109 alignment with EU legislation.
  2. İn Vitro Tanı Amaçlı Tıbbi Cihaz Yönetmeliği — same gazette, transposing EU IVDR 2017/746, same three amendments.
  3. TİTCK announcement 2020/KK-3, 13 February 2020 — validity of EC certificates from UK notified bodies truncated to 31 December 2020 in the national system, with no extension.
  4. TİTCK announcement 2023/KK-6 — registration in ÜTS of the mandate between a manufacturer established outside Türkiye and the EU authorised representative, including the sworn translation requirement and the express exclusion of apostille for that document.
  5. Tıbbi Cihazların Ürün Takip Sistemine Kayıt Süreçlerine İlişkin Kılavuz, version 4.0, 13 May 2026 — registration streams, document requirements, apostille rules for certificates, Turkish instructions for use.
  6. TİTCK 2026 price tariff, version dated 23 March 2026 — all fee amounts on this page.
  7. Tıbbi Cihaz Satış, Reklam ve Tanıtım Yönetmeliği — Resmî Gazete 15 May 2014, no. 29001, last amended 3 July 2026, no. 33299. Articles cited: 5 and 6 application and review periods, 26 the prohibition on selling unregistered devices.
  8. European Commission EUDAMED, notified bodies module — the three bodies established in Türkiye and their MDR designations.
  9. EU–Türkiye Association Council Decision 1/95 establishing the customs union, articles 8, 9 and 11, and Decision 1/2006 as applied by the Customs Union Joint Committee declarations of 21 May and 13 September 2021.
  10. UK–Türkiye Free Trade Agreement, and the exchange of letters amending it, CP 1409, letters dated 7 May 2025 — annexes covering chemicals and motor vehicles. UK Department for Business and Trade updates on the enhanced agreement negotiations, rounds three to five, December 2025 to July 2026.

Re-checked quarterly and after any amendment to the device regulations, any new TİTCK guidance, and each annual tariff. The tariff in particular moves within the year: the 2026 edition on this page is already the third version published in 2026.

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