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Market Availability of Products and Parallel Trade

Counterfeit and illicitly traded health products remained a persistent concern in Türkiye throughout 2025, as reflected both in enforcement statistics and in external reporting on supply chain integrity. Despite the legal prohibition on the online sale of pharmaceutical products, there has been a noticeable increase in the circulation of counterfeit medicines through online channels, alongside growing reports of products being illicitly exported from Türkiye to foreign markets. These trends continue to pose risks to product availability, patient safety, and the overall integrity of the regulated supply chain.

Enforcement activities conducted on the ground in 2025 were, in general, robust and operationally effective. Large-scale seizures and coordinated actions by law enforcement authorities served to prevent millions of counterfeit pharmaceutical products from entering the market. In parallel, authorities and professional stakeholders intensified scrutiny of both online and offline illicit markets where pharmaceuticals, health products, and other regulated items circulate outside formal distribution channels. While different public authorities followed distinct operational roadmaps, criminal enforcement mechanisms proved to be the most effective and deterrent, particularly in cases involving organised illicit trade and large-volume counterfeit distribution.

From an administrative perspective, the Guideline on Products that are Counterfeit, Smuggled, or Outside the Legal Supply Chain, introduced in 2021, was designed to clarify the responsibilities of relevant stakeholders in combating counterfeit, smuggled, and diverted products from a public health and safety perspective. The primary objective of the Guideline is to ensure a multi-stakeholder approach by assigning defined roles to regulatory bodies, industry actors, and other institutional stakeholders in the fight against illegal supply chain activities.

However, practical implementation challenges have limited the Guideline’s overall effectiveness in fully addressing counterfeit pharmaceutical risks in Türkiye. In particular, the Guideline lacks sufficiently detailed operational steps and concrete enforcement mechanisms targeting counterfeit and diverted pharmaceutical products. Moreover, the Ministry of Health and the Agency primarily exercise regulatory and supervisory functions and do not possess direct enforcement powers. As a result, effective and deterrent action against counterfeit pharmaceuticals largely depends on close coordination between the Ministry of Health, the Turkish Medicines and Medical Devices Agency, and enforcement authorities such as the police, gendarmerie, and customs.

Looking ahead, strengthening inter-agency coordination, developing more operationally detailed administrative frameworks, and integrating regulatory oversight with criminal enforcement are likely to remain critical for enhancing supply chain integrity. In this context, a more structured alignment between regulatory monitoring and enforcement action would support a more proactive and deterrent response to the increasing sophistication of counterfeit and illicit pharmaceutical trade affecting the Turkish market.

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