New Restrictions on Child-Oriented Design in Food Products
The Ministry of Agriculture and Forestry updated the Guideline on the Turkish Food Codex Regulation on Food Labelling and Consumer Information on 13 March 2026. The update introduces new explanations regarding labelling, presentation and advertising practices, while adopting a notably protective approach, particularly with respect to products aimed at children.
With the introduction of Article 2.28 into the Guideline, it has been prohibited to place foods on the market with shapes, appearances or packaging that may negatively affect the physical, mental, moral, psychological and social development of children or that may encourage violence. In this respect, the regulation directly focuses on the product itself and its physical presentation.
Under the approach adopted in the Guideline, the assessment is not limited solely to labelling information; rather, the shape of the product, its packaging and its target audience are evaluated together and examined within the framework of a “holistic assessment” principle. In this context, the potential effects on children’s development and the manner in which the product is presented are taken as a basis. As a matter of fact, the Guideline indicates that shapes or packaging such as toilets, weapons, brains, lips, skulls, eyes and feet are not considered appropriate, whereas neutral visuals (such as evil eye beads or smiling emoji-like figures) are not considered to fall within the scope of this provision.
In terms of the practical implications of this approach, it is considered that certain striking packaging and product designs used in products marketed particularly to children may need to be reconsidered. For example, designs used in certain confectionery products on the market targeting children, which refer to the function of the product but at the same time include striking and unusual visuals (such as explosions, body parts or similar associations), may be subject to stricter scrutiny under the new regulation.
On the other hand, although the regulation in question does not directly target advertising content, within the framework of the “holistic assessment” approach adopted in the Guideline, it is possible for the shape and packaging of the product to be considered together with marketing communication. Therefore, considering that packaging and product design are frequently used in advertising content, it is assessed that these restrictions may have indirect effects on advertising and marketing strategies.
As a matter of fact, under the Consumer Protection Law No. 6502 and the Regulation on Commercial Advertising and Unfair Commercial Practices, fundamental principles have also been adopted regarding advertisements directed at children, such as the protection of children’s physical and psychological development, the avoidance of encouraging violence, and refraining from misleading or harmful content. In this respect, it is observed that the regulation introduced into the Food Codex Guideline establishes a protection standard parallel to the existing approach in advertising legislation concerning the protection of children.
In conclusion, considering the strict supervisory approach already adopted by the Advertisement Board in relation to advertisements directed at children, it can be said that this regulation introduced into the Guideline creates a new layer of control operating through product design and packaging. Although the “holistic assessment” principle does not directly regulate advertising content, it has the potential to create a broader area of scrutiny in practice by requiring the relationship between the product, packaging and marketing communication to be assessed together.