Establish device and advertising-environment eligibility first
The product communication scope should identify device status, intended purpose, users and sale conditions. Products from one company may need different advertising decisions. General healthcare promotion advice cannot replace the specific medical-device rules.
Article 15 of Turkey’s current Medical Device Sales, Advertising and Promotion Regulation prohibits consumer advertising for devices exclusively sold, adjusted or applied in specified centres, and for professional-only devices or those requiring application at a sales centre. Consumer advertising for other devices is generally restricted to the online environment where the device is sold; Annex 3 provides a separate exception.
A home-use device is therefore not automatically eligible for an Instagram campaign. Linking to a sales website does not automatically make the upstream advertisement part of that sales environment. Have the responsible compliance owner review the device, Annex 3 status and intended environment. The July 2026 contact-lens online-sales amendment does not generally remove the consumer-advertising prohibition.
Separate professional targeting from verified access
B2B catalog architecture should connect the product group, model and technical document to the appropriate recipient. A purchasing committee may include clinical users, technical personnel and procurement staff; commercial job titles do not automatically satisfy the regulation’s professional definitions.
Article 19 restricts access to electronic professional information to healthcare professionals and technical personnel in healthcare institutions. Selecting a job, interest or industry in an ad set does not verify a person’s status. Controlled document access may support the implementation, but it does not independently establish eligibility for the public advertisement leading to it.
Specific treatment of device information on an authorised sales centre’s official site and certain institution-approved professional announcements is not a blanket B2B advertising exemption. Distinguish distributor, manufacturer and sales-centre responsibilities. Record who may access each document, for which purpose and in which version.
FROM READING TO A NEXT STEP
Document the scope of device communication
Organise models, intended purposes, approved technical sources and access conditions to define a workable website-content scope.
Connect technical statements to traceable evidence
In creative preparation, the chosen claims matter as much as the device image. Model names, accessories, compatibility and intended purpose should match the relevant technical file, label and instructions. Do not reuse a similarly named product’s evidence for another model.
The regulation limits unsupported, exaggerated or misleading claims and promotion outside intended use. Preserve scientific references and their scope. Explain documented conditions instead of promising no risk, certain outcomes or identical success for every user. Comparisons should identify the model version, test conditions and measurement criteria.
| Content | Evidence record | Publication decision |
|---|---|---|
| Model and intended purpose | Label, instructions and relevant technical file | Same product and version |
| Compatibility and accessories | Test conditions and package scope | Explicit limitations |
| Scientific claim | Complete source, date and reviewer | No extension beyond evidence |
| Installation and training | Actual service scope and owner | No unavailable service promise |
| Price or quotation | Validity and sale conditions | Responsible approval before release |
Keep technical requests separate from patient records
The event and field plan should distinguish demonstrations, technical questions and quotation requests without collecting patient information. Company, appropriate role, relevant model and contact preference may suffice. Limit fields to the purpose instead of collecting information simply because it might become useful.
Do not request patient reports, health images, diagnosis or treatment history in the form. Explain that sensitive details should not be entered in free text. Check that such material cannot leak into URLs, event names, parameters or platform-bound records. Server transmission does not independently establish permission to use data.
Customer-list terms prohibit names and criteria containing, implying or based on sensitive health categories. Patient lists and health-inferred segments should not be presented as ordinary retargeting sources. Hashing does not remove that limitation; contact permission and the scope of data use require separate examination.
Record ownership, version and access in the publication decision
The internal review process should let marketing, product and compliance owners inspect the same copy. Review the environment, intended access, claim and destination alongside the design. Platform acceptance does not replace the organisation’s legal and technical review.
Define the scope
Record device, model, purpose, users and publication environment. Distinguish consumer advertising from professional communication at the start.
Match the source
Assign evidence, version, date and responsible reviewer to each claim. Leave unsupported or mismatched statements unpublished.
Inspect access and data
Review professional-document access and request fields. Do not treat ad targeting as identity verification.
Track publication and changes
Keep approved copy, destination and sales responses together. Reassess connected content when the model or evidence changes.
Do not report demonstration requests as purchases
Business-outcome review follows the determination of an eligible advertising scope. Requests, scheduled demonstrations, technical assessments and quotations represent different stages. Counting the first form as a sale or regulatory approval reduces the usefulness of the report.
Internal records should distinguish appropriate organisations, completed discussions, technical scope, the contact’s purchasing role and the next action. Mark an unknown acquisition source as unknown. A platform-attributed result and a verified company sale may not describe the same record set.
Assign responsibility and a removal process for unsuitable or sensitive records before considering platform transmission. Technical-request quality, document access and purchasing progress can be reviewed operationally. Do not convert this into a plan to send clinical details into advertising optimisation.
Tie content changes to the device lifecycle
During catalog maintenance, review retired models, invalid documents and discontinued products together. Updating only the advertisement can leave the website, downloaded files and sales responses contradicting each other.
Periodic review should cover evidence, access scope, form fields and the current responsible owner. A content history helps trace corrections; an earlier approval need not apply to another country or publication environment. International distribution requires a separate review of local rules rather than importing a foreign advertising guide unchanged.
BEFORE YOU DECIDE
Frequently asked questions
Are CE marking and registration sufficient for Meta advertising?
No. Market placement and product conformity differ from permission to advertise to particular people in a particular environment. Review the specific device and proposed publication scope.
Can every home-use device be advertised to consumers?
No. Examine Article 15 distinctions and Annex 3 status. Linking to a sales website does not automatically make a public social-media advertisement eligible.
Does professional targeting verify access?
No. Job or interest selection does not establish professional status. Review electronic professional-content access and the eligibility of the upstream advertisement separately.
Can a demo request count as a sale?
No. Request, suitable discussion, demonstration, technical assessment, quotation and purchase are distinct stages. Preserve definitions and evidence for each stage.
Does consent make a patient list an advertising audience?
A general consent assumption is insufficient. Meta customer-list terms restrict sensitive health criteria; legal conditions and usage rights also need examination. Hashing does not remove these limits.
Does platform approval complete compliance?
No. Platform review is not a final determination of device-law, access or claim eligibility. Responsible company reviewers should document the publication scope.
LET’S DEFINE THE SCOPE
Document the scope of device communication
Organise models, intended purposes, approved technical sources and access conditions to define a workable website-content scope.
Discuss the content scope