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Registering medical devices in Turkey

  • 1.  Registering medical devices in Turkey

    This message was posted by a user wishing to remain anonymous
    Posted 25-Apr-2023 08:17
    This message was posted by a user wishing to remain anonymous

    Hello,

    I'm with Class I medical device manufacturer based in the EU that wants to sell their devices in Turkey.

    We are aware we must register the devices first in the Turkish Product Tracking System (ÜTS).

    However we have not found answer do we need to have a local Turkish representative, a registration holder, to submit the ÜTS registration, or can we do it ourselves.

    Does anyone have experience how this goes?

    We would appreciate your help very much.



  • 2.  RE: Registering medical devices in Turkey

    Posted 26-Apr-2023 10:59

    Good day Anon,

    Turkey (Turkiye) generally follows the requirements of the European Union with the regulations quite similar with some "+" plusses added.  The simple answer is yes, a local Turkiye Authorised Representative is needed if the company does not have a physical location in the country.  A company can either open an office there, then needs to have a "person" which is quoted because there needs to be someone there and available to answer questions if queried by the regulatory authority.  Or you can contract with a third party organisation to provide this service.  It is recommended not to do this with a distributor because conflicts may arise and better to have an independent third-party take on this role.  Also to confirm, Turkiye is not in the European Union but they are various relationships and agreements in place, and is still a separate registration process from CE Marking.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 3.  RE: Registering medical devices in Turkey

    Posted 27-Apr-2023 04:36

    Hello,

    I work with a Turkish manufacturer looking to sell their medical device in EU. Their device was approved by Turkish NB.
    As Richard mentioned you need to have legal representative in the country and someone who will handle any questions from the authorities. Also you will need to translate a lot of documents into Turkish for the submission.

    Have a good day.
    Olga



    ------------------------------
    Olga Peycheva
    Regulatory and Study Start Up Specialist
    Solutions OP Ltd
    olga.peycheva@solutionsop.co.uk
    United Kingdom
    ------------------------------



  • 4.  RE: Registering medical devices in Turkey

    This message was posted by a user wishing to remain anonymous
    Posted 27-Apr-2023 08:21
    This message was posted by a user wishing to remain anonymous

    Richard and Olga, thank you both.

    We had thought EU located manufacturer no need to appoint authorised representative in Turkey.

    That's how we read EU Commission notice to stakeholders last year (here).

    So it's not applicable?




  • 5.  RE: Registering medical devices in Turkey

    Posted 27-Apr-2023 08:09

    In Turkey, foreign manufacturers of medical devices are required to appoint a local authorized representative in Turkey to submit the registration application on their behalf. This representative will be responsible for communicating with the relevant authorities and ensuring that all necessary documents and information are provided to complete the registration process.

    Therefore, you cannot submit the registration application yourself, but you must appoint a local Turkish representative to act as your registration holder and submit the application for you through the Medical Device Tracking System (ÜTS). It is important to note that the representative must be a legal entity established in Turkey and authorized to carry out these activities.



    ------------------------------
    Raje Devanathan
    Amerisource Bergen
    TPIreg, Innomar Strategies
    Senior Manager - Regulatory Affairs, Medical Devices
    rdevanathan@tpireg.com
    3470 Superior Court
    Oakville ON L6L0C4
    Canada
    ------------------------------



  • 6.  RE: Registering medical devices in Turkey

    Posted 28-Apr-2023 05:39

    Hello All,

    I posted a similar question on the forum few months before with no success.
    I agree that you need to select a Turkish rep but the next issue is to register to TITUBB when you are a Class I manufacturer.
    The Turkish website request a CE certificate that you don't have when you are under Class I and it seems it doesn't accept the Declaration of Conformity.
    If someone has a tip how to register to TITUBB when you are class I, I think it is the issue that is raised here...
    Thank you,
    Stephane.



    ------------------------------
    Stephane Berger
    La Ciotat
    France
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  • 7.  RE: Registering medical devices in Turkey

    This message was posted by a user wishing to remain anonymous
    Posted 03-May-2023 07:53
    This message was posted by a user wishing to remain anonymous

    Stephane, thank you sharing your experience.




  • 8.  RE: Registering medical devices in Turkey

    This message was posted by a user wishing to remain anonymous
    Posted 28-Apr-2023 08:07
    This message was posted by a user wishing to remain anonymous

    Raje, thank you.

    Maybe there is confusion with terms 'authorized representative' and 'registration holder'.

    They refer to same legal entity?




  • 9.  RE: Registering medical devices in Turkey

    Posted 10-May-2023 06:04

    Hello,

    Our company has recently analyzed the situation for Turkey. Our conclusions were:
    -Turkey is handled for Medical devices as an EU country, as it has implemented MDR/IVDR and has an recognition agreement in place with EU.
    - Turkish NB can make conformity assessment that is valid for EU.
    - A EC REP appointed for third-party countries is also valid for Turkish authorities.

    I do not see why an EU company would need to appoint an authorized representative in Turkey.

    Have a nice day,
    Enrico



    ------------------------------
    Enrico Schurig
    Epalinges
    Switzerland
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  • 10.  RE: Registering medical devices in Turkey

    This message was posted by a user wishing to remain anonymous
    Posted 12-May-2023 08:15
    This message was posted by a user wishing to remain anonymous

    Thank you Enrico for sharing your conclusions.

    We also do not see why an EU company would need to appoint an authorized representative in Turkey.

    Have a nice day.




  • 11.  RE: Registering medical devices in Turkey

    Posted 06-Mar-2024 07:10

    Hi, Though the reply is late,

    This link will be helpful to you-

    https://health.ec.europa.eu/system/files/2022-04/md_eu-turkey_customs-union_en.pdf

    Conclusion: If you have an Manufacturing site in EU, no need of AR in Turkey.



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    Sushma Polisetty
    senior Lead Consultant
    Bengaluru
    India
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