The short answer is no. Article 13/1 frames the rule in the negative: product placement is not permitted and is allowed only in the programmes listed — it is prohibited, and permitted only where the Law says so.
The four permitted types
Article 13/1: “Apart from films made for cinema and television, series, and sports and general entertainment programmes, practices directed at product placement may not be included in broadcasts. Product placement practices are subject to the rules governing commercial communication.”
| Programme type | Product placement |
|---|---|
| Films made for cinema | Permitted |
| Films made for television | Permitted |
| Series | Permitted |
| Sports programmes | Permitted |
| General entertainment programmes | Permitted |
| News bulletins | Prohibited (Art. 13/4) |
| Children’s programmes | Prohibited (Art. 13/4) |
| Religious programmes | Prohibited (Art. 13/4) |
| Documentaries, discussion, education and all other programmes | Prohibited (Art. 13/1) |
Free goods count as product placement
Article 13/2 contains a much-overlooked provision: “Product placement may also be permitted, under conditions to be determined by the Supreme Council, where certain goods and services are included in a programme free of charge.”
The practical meaning is that using a product in a programme without payment — simply receiving it free — can fall within the product placement regime. “We were not paid, so it is not advertising” does not answer this paragraph. The permission is, however, subject to conditions set by RTUK.
Three conduct prohibitions
Even in the permitted programme types product placement is not unrestricted. Article 13/3 sets three limits:
- Editorial independence. “Product placement shall not be permitted to affect the editorial independence and responsibility of the media service provider.”
- No direct encouragement. “The rental or purchase of products or services may not be directly encouraged.”
- No undue prominence. “There may be no undue prominence given to the product.”
Viewers must be informed
The final sentence of Article 13/3 lists the moments precisely: “Viewers shall be clearly informed of the existence of product placement at the beginning and end of the programme, and when the programme resumes after an advertising break.”
| Moment | Information |
|---|---|
| At the beginning of the programme | Required |
| On each return from an advertising break | Required |
| At the end of the programme | Required |
So a series with two advertising breaks carries four notifications: at the start, on each of the two returns, and at the end.
Products banned from commercial communication cannot be placed
Article 13/5: “The use in product placement of products whose commercial communication is prohibited shall not be permitted.” That is a reference to Article 11. Under Article 11/1 commercial communication is not permitted in any way for alcohol and tobacco products; under Article 11/2 commercial communication may not be made about prescription medicines and treatments. Those products therefore cannot appear by way of product placement in a series or entertainment programme either.
Sanctions
Breach of the product placement provisions falls under Article 32/2: one to three per cent of gross commercial communication revenue, with a floor of TRY 1,000 for radio and TRY 10,000 for television and on-demand services. The second track of Article 32/5 singles out commercial communication provisions: more than twenty breaches of any of them within a year leads to suspension of up to five days, rising on repetition and ending in licence revocation on a second repetition.
The absolute ban in news is covered in the news guide and the distinction from sponsorship in the sponsorship guide.