Turkish Food Codex Regulation on Flavourings: A New Framework for the Food Sector Introduction

Introduction

The Turkish Food Codex Regulation on Flavourings and Food Ingredients with Flavouring Properties (“Regulation”), published by the Ministry of Agriculture and Forestry (“Ministry”) in Official Gazette No. 33370 dated 14 September 2026, introduces a comprehensive framework governing the conditions of use of flavourings and food ingredients with flavouring properties, their source materials, the production conditions applicable to smoke flavourings, and labelling requirements.

The Regulation was issued pursuant to Articles 23, 24 and 26 of Law No. 5996 on Veterinary Services, Plant Health, Food and Feed (“Law No. 5996”). Its primary purpose is to establish the conditions of use and labelling requirements applicable to flavourings and food ingredients with flavouring properties, with a view to protecting human health and consumer interests, ensuring fair practices in food trade, and taking environmental considerations into account.

The Regulation was also prepared within the framework of alignment with European Union legislation and contains detailed provisions governing the use, authorisation and labelling of flavourings and food ingredients with flavouring properties.

Key Provisions

The Regulation applies to flavourings used or intended for use in foods, food ingredients with flavouring properties, foods containing such products, source materials for flavourings and food ingredients with flavouring properties, and the production conditions applicable to smoke flavourings.

However, substances having exclusively a sweet, sour or salty taste and unprocessed foods fall outside the scope of the Regulation. Non-compound foods, such as fresh, dried or frozen spices and/or herbs, tea blends and mixtures for infusion, as well as mixtures thereof, are also excluded, provided that they are consumed as such and/or are not used as food ingredients.

The Regulation provides detailed definitions of key concepts, including flavour precursor, flavouring, flavouring substance, flavouring preparation, food ingredient with flavouring properties, natural flavouring substance, thermal process flavouring, smoke flavouring, smoke flavouring derivatives, other flavouring and source material. It also includes definitions relating to CAS, CoE, EINECS, FEMA, FL and JECFA numbers.

The Regulation distinguishes between “evaluated flavouring substances” and “flavouring substances under evaluation”. Flavouring substances undergoing risk assessment may continue to be placed on the market and used in foods, subject to the conditions prescribed by the Regulation, until the assessment is completed and the substance is either included in Annex 1, Part A, Table 1 as an evaluated flavouring substance or removed from the list.

Under the general provisions of the Regulation, only flavourings or food ingredients with flavouring properties that, based on available scientific evidence, do not pose a safety risk to consumers and whose use does not mislead consumers may be used in foods. Flavourings that do not comply with the Regulation, as well as foods containing non-compliant flavourings and/or food ingredients with flavouring properties, may not be placed on the market.

In addition, flavourings and food ingredients with flavouring properties of porcine or insect origin, as well as source materials used in their production, may not be used in foods. Products falling within the scope of the Regulation may not be used in a manner that misleads consumers in foods served or packaged at retail food establishments at the consumer’s request, nor may they be placed on the market under the name of any alcoholic beverage or alcoholic beverage category.

Specific Conditions of Use

Article 6 of the Regulation establishes specific conditions of use and restrictions applicable to certain substances, source materials and flavourings.

In this context:

• Substances listed in Annex 3, Part A may not be added to foods as such.
• The maximum levels of certain substances that may be present in certain compound foods as a result of the addition of flavourings or food ingredients with flavouring properties are set out in Annex 3, Part B.
• Source materials listed in Annex 4, Part A may not be used in the production of flavourings or food ingredients with flavouring properties.
• Flavourings and food ingredients with flavouring properties obtained from source materials listed in Annex 4, Part B may only be used under the conditions specified in that Part.
• The production conditions for thermal process flavourings and the maximum levels of certain substances that may be present in such products must comply with Annex 5.

Conversely, certain products specified in Article 6 may be used without undergoing a separate evaluation and authorisation process, provided that they satisfy the general requirements relating to safety and non-misleading use. These include, subject to the applicable conditions, flavouring preparations obtained from food, thermal process flavourings obtained from food and complying with Annex 5, flavour precursors obtained from food, and food ingredients with flavouring properties.

However, where the Ministry or the Scientific Commission has concerns regarding the safety of such a flavouring or food ingredient with flavouring properties, the relevant product will be subject to a risk assessment. The Ministry will conduct its assessment in accordance with the opinion of the Scientific Commission and, where a risk is identified, emergency measures may be taken where necessary.

Authorisation and Use System

The Regulation requires certain flavourings and source materials to undergo evaluation and authorisation by the Ministry.

This requirement applies to:

• flavouring substances;
• flavouring preparations obtained from certain non-food source materials;
• certain thermal process flavourings falling within the scope specified in the Regulation;
• certain flavour precursors obtained from non-food source materials;
• other flavourings; and
• certain non-food source materials.

Flavourings and source materials subject to evaluation and authorisation by the Ministry under Article 7 of the Regulation are listed in Annex 1. For products falling within this category, only flavourings and source materials included in Annex 1 may be placed on the market and used in foods, subject to the conditions of use specified in the Regulation.

Accordingly, inclusion in Annex 1 is not a general requirement applicable to all flavourings. Food business operators must first determine the category into which the product they use falls under the Regulation and whether it is subject to evaluation and authorisation by the Ministry.

For a flavouring or source material falling within the scope of the Regulation on Genetically Modified Organisms and Products to be included in Annex 1, it must also be authorised under the applicable GMO legislation.

Smoke Flavourings

The Regulation also introduces specific production requirements for smoke flavourings. The production conditions applicable to primary products must comply with Annex 6. Smoke flavouring derivatives may be produced by further processing, through appropriate physical processes, of primary products designated by the Ministry.

In addition, the water-insoluble oily phase generated as a by-product during the production of primary products may not be used in the production of smoke flavourings.

Who Is Affected?

The Regulation affects a broad range of businesses operating in the food sector in connection with the production, importation, supply or use of flavourings in foods.

In particular:

• businesses that produce or import flavourings;
• businesses that distribute or supply flavourings;
• food manufacturers that use flavourings or food ingredients with flavouring properties in their products; and
• businesses that produce or use smoke flavourings or their primary products

should assess their products, supply chains and production processes in light of the requirements of the Regulation.

Labelling Requirements

The Regulation introduces detailed requirements for the labelling of flavourings.

Labels of flavourings not intended for sale to the final consumer must include, among other information:

• the term “flavouring” or a more specific name or description of the flavouring;
• the statement “for food use”, “restricted use in food”, or a more specific indication of the food for which the flavouring is intended;
• where necessary, special storage, preservation or conditions of use;
• the batch mark or number;
• information on the product composition;
• details of the manufacturer, packager, importer or distributor;
• information on components subject to quantitative restrictions on use;
• the net quantity;
• the best-before date or use-by date; and
• allergen information, where required.

Provided that the statement “not for retail sale” appears in a readily visible position on the packaging, certain information concerning composition and use may be provided in documents accompanying the consignment or supplied to the purchaser before delivery. Where flavourings are supplied in tankers, all relevant information may be provided in the documents accompanying the consignment.

Products falling within the scope of the Regulation and intended for sale to the final consumer must be labelled in accordance with the applicable legislation on food labelling, GMOs and lot identification. In addition, pursuant to Article 13(2) of the Regulation, where flavourings are offered for sale to the final consumer either individually or mixed with other flavourings, food ingredients or other added substances, their packaging must bear the statement “for food use”, “restricted use in food”, or a more specific indication of the food for which the flavouring is intended.

Use of the Term “Natural”

The Regulation establishes detailed criteria for the use of the term “natural” in relation to flavourings. For the term “natural” to be used together with a reference to a specific food, food category, or plant or animal flavouring source, all or at least 95% by weight of the flavouring components must be obtained from the referenced source.

The Regulation also specifies the circumstances in which terms such as “natural flavouring substance(s)”, “natural flavouring” and “other natural flavourings” may be used.

Specific Labelling Requirements for FL 16.133

Article 14 of the Regulation introduces specific labelling requirements for flavouring substance FL 16.133 and flavourings containing this substance that are not intended for sale to the final consumer.

The packaging or containers of such products must bear the statements “Contains flavouring substance FL 16.133. Protect from light to prevent photoconversion” and “Keep away from light”.

Reporting and Notification Obligations to the Ministry

In addition to product and labelling compliance requirements, the Regulation imposes certain reporting and notification obligations on companies. Upon request by the Ministry, the user or producer of an authorised flavouring substance that remains under evaluation must inform the Ministry, within twelve months, of the quantity of the flavouring substance added to food.

Furthermore, where there is a significant change in the production method or starting materials of a listed flavouring compared with the conditions on which the risk assessment was based, the necessary documentation must be submitted to the Ministry for evaluation before the flavouring is placed on the market.

A producer or user of flavourings and/or source materials must immediately notify the Ministry upon becoming aware of any new scientific or technical information that may affect the safety assessment of a flavouring substance. Additives, carriers and solvents required for the production, storage and use of flavourings must also comply with the Turkish Food Codex Regulation on Food Additives.

What Should Companies Do?

In this context, the key compliance measures that companies operating in the food sector should prioritise can be summarised as follows:

• Classify flavourings and food ingredients with flavouring properties used in existing product formulations in accordance with the definitions and categories set out in the Regulation.
• Determine whether the flavourings used are subject to evaluation and authorisation by the Ministry and verify the Annex 1 status of products falling within this scope.
• Assess whether products exempt from evaluation and authorisation under Article 6 satisfy the applicable conditions.
• Review products for prohibited substances and maximum levels specified in Annex 3.
• Assess source materials against the requirements of Annex 4.
• Where thermal process flavourings are used, verify compliance with Annex 5.
• Where smoke flavourings or primary products are used, assess production processes for compliance with Annex 6 and the relevant specific provisions.
• Identify products containing flavouring substances under evaluation and monitor the status of those substances.
• Review existing product and flavouring labels for compliance with Article 13.
• Verify compliance with the specific labelling requirements under Article 14 for products containing flavouring substance FL 16.133.
• Update technical specifications, origin information, source material documentation and compliance documents obtained from suppliers.
• Verify that additives, carriers and solvents comply with the applicable food additives legislation.
• Establish the necessary internal reporting and notification procedures for responding to Ministry information requests and addressing new scientific or technical information.
• Identify products containing flavouring substances specifically regulated under the transitional provisions.

Transitional Period and the 31 December 2026 Deadline

Food business operators operating within the scope of the Regulation must comply with its provisions by 31 December 2026.

Food business operators that were already operating before the publication of the Regulation must continue to comply with the provisions of the previous Turkish Food Codex Regulation on Flavourings and Food Ingredients with Flavouring Properties, repealed by Article 19 of the new Regulation, until they achieve compliance with the new Regulation.

Products placed on the market before 31 December 2026 by food business operators that were operating before the publication of the Regulation, as well as foods containing such products, may remain on the market until the end of their shelf life.

Specific Transitional Rules for Certain Flavouring Substances

Flavouring substances FL 04.029, FL 05.100, FL 05.175, FL 05.222, FL 15.029, FL 15.030, FL 15.060, FL 15.119, FL 15.130 and FL 15.131 may not be placed on the market or used in food production as of 31 December 2026.

As of the same date, the importation of these flavouring substances and foods containing any of them will also no longer be permitted. However, foods containing any of these substances that were placed on the market before 31 December 2026 may remain on the market throughout their shelf life.

The Regulation nevertheless provides for an important exception. Compound flavourings produced before 31 December 2026 that contain any of the above flavouring substances and may also contain other food ingredients, such as food additives, enzymes and carriers, for the purposes of storage, sale, standardisation, dilution or facilitating dissolution may continue to be used in food production throughout their shelf life.

Specific Provisions for FL 05.062 and FL 05.099

As of 31 December 2026, flavouring substances FL 05.062 and FL 05.099 may only be used in the food categories specified in Annex 1, Part A, Table 1 of the Regulation.

Foods containing flavouring substances FL 05.062 or FL 05.099 that were placed on the market before the publication of the Regulation may remain on the market throughout their shelf life.

Administrative Sanctions

Pursuant to Article 17 of the Regulation, administrative sanctions for non-compliance with the Regulation will be imposed in accordance with the relevant provisions of Law No. 5996.

Companies should therefore not limit their compliance efforts to product formulations and labels. Their procurement, importation, production, source material, technical documentation, reporting and notification processes should also be reviewed for compliance with the Regulation.

Conclusion

The new Regulation significantly updates the previous regulatory framework governing the use of flavourings and food ingredients with flavouring properties and introduces detailed requirements concerning product classification, evaluation and authorisation procedures, source material restrictions, limits on use, the production of smoke flavourings, labelling, reporting and transitional arrangements. In particular, the requirement to achieve compliance by 31 December 2026 requires food business operators to promptly assess their existing products and production processes. However, the transitional framework is not limited to this deadline and includes different rules applicable to certain flavouring substances, flavouring mixtures and food categories.

You can accsess the full text of the Regulation, which is only in Turkish, here.