Guideline on the Turkish Food Codex Regulation on Food Labelling and Consumer Information Updated

The Ministry of Agriculture and Forestry has introduced significant updates to the Guideline on the Turkish Food Codex Regulation on Food Labelling and Consumer Information. The update provides further clarification on labelling, presentation, and advertising practices, while adopting a notably protective approach, particularly in relation to products targeting children.

Key Amendment (Restrictions on Presentation Directed at Children)

With the introduction of Article 2.28, it is now explicitly prohibited to place foods on the market with shapes, appearances, or packaging that may negatively affect the physical, mental, moral, psychological, or social development of children, or that may encourage violence.

In this context:

• Product assessments will not be limited to labelling alone; rather, the product shape, packaging, advertising content, and target audience will be evaluated holistically.
• The assessment will be based on the potential impact on children’s development, as well as the nature of the marketing communication and the manner in which the product is presented.
• The use of shapes or packaging resembling toilets, weapons, brains, lips, skulls, eyes, feet, etc. is considered inappropriate.
• Conversely, neutral visuals such as evil eye beads or smiling emoji-like figures are not considered within the scope of this restriction.

Other Notable Points

• Restrictions on the use of the term “cream” for products falling outside the scope of the relevant Communiqué have been clarified.
• The requirement to clearly indicate preparation instructions on the labels of herbal teas has been emphasized.
• Obligations regarding the disclosure of ingredient and energy information in mass catering establishments, along with applicable transition periods, have been further detailed.

Assessment
The newly introduced approach under Article 2.28, particularly regarding restrictions on presentation directed at children, necessitates a reassessment of product design and marketing strategies from a child protection perspective. While the Guideline includes illustrative examples, the adoption of a “holistic assessment” criterion is expected to broaden the scope of regulatory scrutiny in practice