ARTICLE
25 September 2026

A New Era For Refurbished Products

FE
Fidanci & Esin Partners

Contributor

F&E Partners is a next-generation boutique law firm based in Istanbul, delivering full-spectrum legal solutions across diverse practice areas, including but not limited to dispute resolution, corporate, regulatory, and real estate matters. Combining international experience with meticulous local expertise, we offer agile, partner-led counsel and strategic insight to help clients thrive in a dynamic legal and business landscape.
The Regulation on Refurbished Products (“Regulation”), published in the Official Gazette dated 27 June 2026 and numbered 33293, entered into force on 1 August 2026. The Regulation repealed the Regulation on the Sale of Refurbished Products, which had constituted the main regulatory framework for the refurbished products market since 22 August 2020, and substantially reorganized the system governing the refurbishment, certification and sale of refurbished products.
Turkey Consumer Protection

The Regulation on Refurbished Products (“Regulation”), published in the Official Gazette dated 27 June 2026 and numbered 33293, entered into force on 1 August 2026. The Regulation repealed the Regulation on the Sale of Refurbished Products, which had constituted the main regulatory framework for the refurbished products market since 22 August 2020, and substantially reorganized the system governing the refurbishment, certification and sale of refurbished products.

While essentially retaining the system of refurbishment centers and authorized sellers established under the previous regulation, the new Regulation introduces significant changes, including the expansion of consumers’ right of withdrawal, the introduction of the Refurbished Product Information System (“YÜBİS”), the expansion of the range of products eligible for refurbishment and stricter requirements for refurbishment centers.

1. What Is a Refurbished Product and Which Products Can Be Refurbished?

Under the Regulation, a refurbished product means a used good offered for resale by a refurbishment center or an authorized seller after undergoing refurbishment in accordance with the prescribed standards.

Refurbishment operations cannot be carried out freely by just any seller or service provider. These activities may be carried out by refurbishment centers holding a refurbishment authorization certificate issued by the Ministry of Trade (“Ministry”) and by on-site refurbishment points operating under those centers pursuant to the Regulation. Refurbished products may be offered to consumers directly by a refurbishment center or through authorized sellers appointed by the center.

Under the new Regulation, televisions have been included among the products that may be refurbished and offered for sale, in addition to mobile phones, tablets, smart watches, laptop and desktop computers, game consoles and modems. Accordingly, televisions have been added to the six product groups covered by the 2020 regulation, as last amended.

The packaging, labels, advertisements and listings for a refurbished product must indicate that the product is “refurbished” and provide information on the center that refurbished it in a manner easily visible to consumers. Refurbished products must also be offered for sale in a separate category so that they can be distinguished from unused products and other second-hand products. Whereas the repealed regulation prescribed this obligation only for distance sales, the new Regulation extends this separation requirement to all sales channels.

2. The Refurbishment Process Will Be Digitally Monitored through YÜBİS

One of the structural changes introduced by the new Regulation is the establishment of the Refurbished Product Information System (YÜBİS).

It has become mandatory to carry out refurbishment operations through YÜBİS and to generate an electronic certificate for the refurbished product. Information on refurbishment centers, on-site refurbishment points and authorized sellers, together with other information and documents specified by the Ministry, will also be recorded in the system.

Accordingly, the system operated through various notification, record-keeping and certification obligations under the previous regulation is being replaced by a structure in which the refurbishment process can be monitored more comprehensively through a single centralized information system. The Ministry has also announced that operations performed on devices, replaced parts, records of inquiries regarding lost, smuggled or stolen devices, information on refurbishment centers and businesses acting on their behalf, and product certificates will be recorded through YÜBİS, and that the relevant information will be made accessible to consumers.

For used products with electronic identification information (e.g., IMEI), the Regulation requires, among other conditions, that the device be activated using a line declared to YÜBİS and that at least one successful call be made through that line. The relevant verifications will be carried out through YÜBİS via the systems of the Information and Communication Technologies Authority.

3. A 14-Day Right of Withdrawal Also Applies to Refurbished Products Purchased in Stores

One of the most significant changes introduced by the new Regulation for consumers is the expansion of the scope of the right of withdrawal.

The Regulation on Distance Contracts continues to apply to the right of withdrawal in distance sales. However, the new Regulation also grants consumers the right to withdraw from the contract within 14 days of delivery, without providing any reason or paying any contractual penalty, for refurbished products purchased through other sales methods, such as physical stores.

The repealed 2020 regulation did not provide for such a general right of withdrawal for in-store sales of refurbished products. The provision therefore significantly reduces the difference in consumer protection between distance and physical sales channels in respect of refurbished products.

Where consumers are not duly informed of their right of withdrawal or the obligations prescribed by the Regulation regarding the right of withdrawal are breached, consumers are not bound by the 14-day period. In such cases, the right of withdrawal expires one year after the date on which the ordinary withdrawal period ends. If consumers are duly informed within that period, the 14-day withdrawal period begins on the date on which the information is provided.

4. The Warranty and After-Sales Services Regime Has Been Reorganized

As under the previous regulation, the warranty period for refurbished products will continue to be at least one year from delivery to the consumer. Requests for free repair or replacement with a non-defective refurbished equivalent must be fulfilled within a maximum of 20 business days, with this period starting when the product is delivered to the authorized seller or the refurbishment center.

However, the new Regulation addresses the warranty regime within a different framework from the previous regulation and expressly provides that the warranty provisions of Law No. 6502 on Consumer Protection and the Warranty Certificate Regulation will apply mutatis mutandis to refurbished products. In this context, the responsibilities of the manufacturer, importer and authorized service provider will be fulfilled by the refurbishment center, while the obligations of the seller will be fulfilled by the authorized seller.

The authorized seller is held jointly and severally liable with the refurbishment center for the fulfillment of the rights granted to consumers under the Regulation.

5. Requirements for Refurbishment Centers Have Been Tightened

The new Regulation has also tightened the requirements relating to the corporate and financial structure of refurbishment centers.

Whereas the previous regulation required a minimum paid-in capital of TRY 30 million to obtain a refurbishment authorization certificate, the new Regulation has increased this amount to TRY 100 million. It has also become mandatory for refurbishment centers to be capital companies (i.e., joint stock or limited liability companies), and the system for monitoring compliance with the authorization requirements has been reorganized. The commission established within the Ministry has been empowered to decide on warnings and the cancellation of authorization certificates; cancellation of the authorization certificate is prescribed where a violation continues despite a written warning.

Transitional provisions have also been introduced for existing refurbishment centers operating on the date on which the Regulation entered into force. Accordingly, documents demonstrating compliance with the requirements concerning the qualification certificate, capital company status and company representatives must be submitted to the General Directorate of Consumer Protection and Market Surveillance within one month of the Regulation’s entry into force, while documents concerning the minimum capital requirement of TRY 100 million and other matters to be announced by the Ministry must be submitted by 31 December 2026. Existing authorization certificates may continue to be used until the end of their validity periods without obtaining a new authorization certificate.

6. Other Significant Changes

The new Regulation also prohibits a refurbished product from being refurbished again until at least 30 days have elapsed from the date of refurbishment. This aims to prevent the same product from being repeatedly placed on the market as a refurbished product within short periods. The repealed regulation expressly allowed the same product to be refurbished more than once but did not prescribe any minimum period between refurbishments.

Where the same seller applies different prices to the same product group, the physical and technical characteristics underlying the price difference must be disclosed clearly and in an easily visible manner before the consumer assumes any payment obligation.

The system governing the purchase of used products from consumers for refurbishment has also been reorganized. While retaining the three-business-day valuation period provided for in the previous regulation, the new Regulation has expanded the scope of the related obligations and introduced more detailed rules for refurbishment centers, on-site refurbishment points, authorized sellers and third parties acting on behalf of refurbishment centers. In addition, discounts, coupons or similar economic benefits promised to consumers must be provided within three business days following the consumer’s approval; for contracts involving a trade-in, this period begins when the consumer fulfills their obligations relating to the transaction.

7. Conclusion

The Regulation on Refurbished Products, which entered into force on 1 August 2026, restructures the refurbished products system established in 2020 around digital records, stricter authorization and broader consumer rights, rather than abandoning that system entirely.

In particular, making the refurbishment process for devices traceable through YÜBİS, introducing a 14-day right of withdrawal for in-store sales as well, distinguishing refurbished products more clearly from other second-hand products, and strengthening the capital and authorization requirements for refurbishment centers constitute the key elements of the new era.

In this context, the new Regulation strengthens the regulatory approach aimed at transforming the refurbished products market from a market merely for the resale of second-hand products into a distinct sales model subject to specific technical standards, a centralized record system, warranty obligations and special consumer protection rules.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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