In Türkiye, licensed plant protection products, pesticides included, cannot be sold or promoted online or on social media. Article 7 of the regulation published on 13 December 2025 also covers listings, price promotions, videos and images. A licence holder records the listing, reports it to the marketplace as illegal content, adds a trademark complaint if the product is counterfeit, and reports it to the Provincial Directorate of Agriculture and Forestry.
What exactly does the regulation prohibit?
The basis is the Regulation on the Wholesale and Retail Sale and Storage of Plant Protection Products, in Official Gazette No. 33106. It took effect thirty days after publication and repealed the 2019 regulation. A 1 July 2026 date was set for certain provisions tied to the prescription scheme piloted in selected provinces; Article 7 is not among those deferred provisions.
Article 7 provides that:
- Licensed products may not be promoted or sold over the internet or through social media; no listing may be posted for promotion, sale, price discount or any other purpose, and no video or image may be shared.
- A licence holder, dealer, wholesaler, manufacturer or distributor may not open a website to sell these products.
- Products without Ministry approval may not be presented or sold as plant protection products.
- Products that have been withdrawn or banned may not be promoted or sold.
- The only exception is a licence holder's promotion on its own website, using information from the approved label.
Article 6 sets the sales chain: licence holders sell only to authorized dealers and wholesalers, wholesalers only to dealers, dealers only to users. Sales outside premises registered with the Ministry, or from mobile points, are not allowed.
Article 45 links breaches of the first two paragraphs of Article 7 to Article 39(1)(f) of Law No. 5996, which provides for an administrative fine and seizure of the products. Article 43 lists tracking internet sales among the duties of control officers.
Which route fits which listing?
Using a trademark complaint against a seller of genuine product can backfire.
| Listing type | Basis | Where to report | Watch out for |
|---|---|---|---|
| Genuine product, unauthorized seller | Regulation Art. 7, Law No. 6563 Art. 9(2) | Marketplace, Provincial Directorate | A trademark complaint is weak against a seller with an invoice |
| Counterfeit product or imitation of your brand | Law No. 6769 Arts. 7 and 29, Law No. 6563 Art. 9(3) | Marketplace, Provincial Directorate, prosecutor if needed | Needs a registration certificate; the seller can object |
| Unlicensed product sold as a pesticide | Regulation Arts. 5 and 7(3) | Provincial Directorate, marketplace | No trademark route if your brand is not used |
| Your own dealer's social media post | Regulation Art. 7(1), dealer contract | Write to the dealer first | Decide on reporting with legal |
The warning in the first row comes from Article 152 of Law No. 6769: acts relating to goods put on the market by or with the consent of the right holder fall outside the trademark right, unless the goods have been altered. If the seller objects with an invoice, the product returns, and a second complaint on the same claim is not processed without new documents. That rule is covered in how to file a counterfeit complaint on a marketplace. The problem here is the online sale itself, so the file should argue that.
Does the marketplace have to remove the listing?
Under Article 9 of Law No. 6563, a marketplace that becomes aware that a seller's content is illegal must remove it without delay and notify the relevant public bodies. Article 10 of the implementing regulation caps that at 48 hours.
There is a limit. The regulation names notices from the Ministry and from public bodies within their remit among the cases where a marketplace is deemed aware; it does not name a licence holder's notice. The list is illustrative, but a private notice may not always have the same effect, so run the marketplace notice and the Provincial Directorate report at the same time.
In the notice, cite Article 7, give the full listing URL, and state that the product is a licensed plant protection product and that your company holds the licence.
What changes on social media?
The regulation names social media expressly, but the marketplace duty in Law No. 6563 does not apply to social networks. Where your brand or logo is used, the platform's trademark and counterfeit forms apply, and those need a registration. Otherwise you are left with the platform's general reporting channel, and results vary. See our guide to fake Instagram stores.
Additional Article 4 of Law No. 5651 requires social network providers with more than one million daily visits from Türkiye to answer applications within 48 hours, with reasons if the answer is negative. That is a deadline to respond, not to remove. If the sale moves to a messaging app, add the number from the listing to your Provincial Directorate file.
What should the ministry file contain?
The report goes to the Directorate of Agriculture and Forestry in the seller's province. If the province is unknown, you can write to the General Directorate of Food and Control, the unit named in the regulation. Include:
- The full listing URL, a dated screenshot and the platform name.
- The seller's name, store address and any phone or account details in the listing.
- The product name, licence holder details and the label as shown.
- The QR code image, if readable. The regulation requires an approved label and QR code on packaging for products subject to the QR code rule.
- If the product looks counterfeit, a short note on why.
For how to capture the record, see does a screenshot count as evidence?. The Ministry runs any inspection and sanction; the licence holder only provides information.
What about your own channels?
A complainant's own channels need to be clean too. Since the only exception is label-based promotion on your own website, review product-focused social posts and the image packs you give dealers with your legal team. Writing the ban into dealer contracts makes later conversations easier.
What does Authex do in this process?
Authex scans Turkish marketplaces and social media for listings using your product names and images, records the URL, seller details and a screenshot, ranks findings by risk and assigns them to your team. It drafts platform notices; the licence holder or its lawyer files them and any report to the Ministry. Authex does not verify a product's licence status or contents. See the marketplace monitoring page.
Sources
- Regulation on the Wholesale and Retail Sale and Storage of Plant Protection Products, Official Gazette No. 33106, 13 December 2025 (in Turkish)
- Law No. 5996 on Veterinary Services, Plant Health, Food and Feed (mevzuat.gov.tr, in Turkish)
- Law No. 6563 on the Regulation of Electronic Commerce (mevzuat.gov.tr, in Turkish)
- Regulation on Electronic Commerce Intermediary Service Providers and Service Providers, Official Gazette, 29 December 2022 (in Turkish)
- Industrial Property Law No. 6769 (mevzuat.gov.tr, in Turkish)
- Law No. 5651 (mevzuat.gov.tr, in Turkish)
