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CE Compliance in Turkish: Why the Machinery Directive Does Not End at the Border

By Vedat Güven, Mechanical Engineer, Technical and Quality Advisor, Alafranga Language Solutions. Across a career spanning aerospace and defence, oil and gas, energy, automotive and heavy industry, he has held roles in supplier quality assurance, quality management, QA/QC, test and verification systems, non-destructive testing (NDT), HSE and international audits.
 
A CE mark on a machine means that the manufacturer has declared conformity with the applicable European legislation: the machine meets the essential health and safety requirements, a technical file exists, and the conformity assessment procedure has been completed. For most European markets, the CE mark is the end of the documentation process.
 
For Turkey, it is the beginning of a second one.
 

 

Turkey implements EU machinery legislation through its own Machine Safety Regulation (Makine Emniyeti Yönetmeliği), issued by the Ministry of Industry and Technology. Until now, the 2009 version, aligned with Directive 2006/42/EC, has applied. On 16 October 2026, the new version aligned with Regulation (EU) 2023/1230 was published in the Official Gazette No. 33402, and like the EU Regulation it applies from 20 January 2027. The essential health and safety requirements and the conformity assessment procedures are the same as in the EU. A CE-marked machine exported to Turkey is generally recognised without re-certification.
 
What is not recognised is documentation in any language other than Turkish.
 
The Turkish regulation is explicit: the instructions for use, kullanım kılavuzu, must be provided in Turkish. This is not a market preference or a distributor requirement. It is a legal obligation, and it applies to every machine placed on the Turkish market, regardless of whether the machine carries a CE mark and regardless of whether full documentation in other languages is also provided.
 
For European manufacturers with established CE documentation processes, this creates a specific and recurring problem. The technical file exists. The instructions are complete. The declaration of conformity is signed. And then, at the point of market entry into Turkey, the documentation process has to begin again: in Turkish, against Turkish regulatory expectations, with terminology requirements that the European process was not designed to address.
 

▮What the Turkish regulation actually requires

The Machine Safety Regulation requires that machinery placed on the Turkish market be accompanied by instructions in Turkish covering, at minimum: the intended use and foreseeable misuse of the machine, assembly and installation conditions, commissioning and operating procedures, maintenance and repair instructions, information about residual risks, and the warning and safety information required by the essential health and safety requirements.
 
Structurally, this is the same content that EU legislation requires in the instructions for use. The difference is that in Turkey this content must be in Turkish, and it must meet the terminology expectations of Turkish technical regulators and, where applicable, Turkish standards bodies.
 
The declaration of conformity, uygunluk beyanı, must also be provided in Turkish. It follows a format defined in the regulation, including the exact wording of the declaration statement. A declaration translated from a European language without reference to these format requirements will often contain wording that is technically accurate but does not match the expected regulatory formula, which creates questions during customs clearance or market surveillance that would not otherwise arise.
 
Beyond the machinery regulation, machines placed on the Turkish market may also be subject to Turkish standards, the TS EN adoptions of the harmonised European standards, and the documentation may be expected to use the terminology defined in those standards. The relationship between harmonised standards and their TS EN adoptions is close but not identical, and terminology alignment requires active verification rather than assumption.
 

▮The technical file is not a translation project

This is the point where the framing of the task matters most.
 
European manufacturers typically think of Turkish documentation as a translation project: take the existing CE documentation, translate it into Turkish, distribute it with the product. The framing is understandable. It is also the source of most of the problems that surface later.
 
A CE technical file is a structured body of documentation: drawings, calculations, risk assessments, test reports, the instructions for use, the declaration of conformity and supporting technical records. Not all of it needs to be translated for Turkish market entry. What needs to be translated, and how, depends on the product category, the applicable legislation, the nature of the Turkish customer relationship, and whether the product will be subject to market surveillance.
 
The instructions for use must be in Turkish; this is non-negotiable. So must the declaration of conformity. The rest of the technical file may remain in the original language, provided that it is available for inspection if Turkish market surveillance authorities request it. But the documents that accompany the product to the end user must be in Turkish, and they must be correct, not just linguistically, but in format, terminology and regulatory alignment.
 
Treating this as a straightforward translation project (send the files, receive the Turkish text, attach it to the product) produces documentation that is translated but not necessarily compliant. The difference only becomes visible when something goes wrong: a customs question, a market surveillance inspection, an incident involving the machine, or a distributor who needs to submit documentation to a Turkish authority.
 

▮Where Turkish documentation most often fails

We have worked with Turkish technical documentation for European manufacturers since 2002, and the failure points are consistent and predictable.
 
  • Declaration of conformity wording. The Turkish uygunluk beyanı has a defined format and defined language: the phrase used to declare conformity, the way the manufacturer's identity is stated, the way the applicable legislation is referenced, and the format of the authorised representative's statement. A declaration translated from German or English without reference to these conventions is often semantically correct but formally non-standard, and immediately recognisable to a Turkish customs officer or market surveillance inspector as a document prepared by someone unfamiliar with Turkish regulatory documentation.

  • Safety warnings and signal words. DANGER, WARNING and CAUTION correspond to TEHLİKE, UYARI and DİKKAT, as defined in the Turkish adoptions of the applicable standards. A translation that renders WARNING as UYARI in one place and İKAZ in another, both plausible Turkish words, creates an inconsistency that signals unfamiliarity with those standards. Some translators still prefer the older İKAZ, but in safety documentation signal word consistency is not a style preference; it is a safety requirement.

  • Residual risk statements. The instructions must include information about residual risks that cannot be eliminated by design or safeguarding. The way the risk is described and the required protective measures are specified follows conventions in Turkish technical documentation that a general translator may not know. Residual risk statements translated too literally from German or English read awkwardly in Turkish and fail to reach a Turkish operator or safety officer in the way they expect.

  • Maintenance and service values. Torque specifications, pressure ratings, temperature ranges and service intervals survive translation intact, but the way they are written may not. Turkish, like German, uses the decimal comma. A maintenance manual that uses a full stop as a decimal separator throughout, English unit abbreviations in Turkish instructional text, or the wrong spacing between value and unit is immediately recognisable as a document not prepared by a translator who works regularly with Turkish technical documentation.

▮Partly completed machinery and the declaration of incorporation

Machinery legislation includes a specific provision for partly completed machinery: assemblies that cannot function independently and are intended to be incorporated into a complete machine. For these, a declaration of incorporation is required instead of a declaration of conformity, together with assembly instructions that enable safe incorporation.
 
The Turkish regulation mirrors this structure. The provisions for kısmen tamamlanmış makine (partly completed machinery) follow EU legislation, including the requirement for a declaration of incorporation in Turkish. Under the new 2026 regulation they follow the sharpened definitions of Regulation 2023/1230, and the Turkish terminology will shift with them.
 
This matters because partly completed machinery is common in industrial supply chains. A European manufacturer supplying a sub-assembly to a Turkish systems integrator, or a Turkish machinery builder incorporating European components, will meet this provision. It is frequently overlooked, partly because it is discussed less than the main requirements, and partly because the Turkish terminology is unfamiliar to European documentation teams. For what else the new Regulation changes in documentation, see The EU Machinery Regulation 2023/1230.
 

▮The distributor gap

European manufacturers frequently rely on their Turkish distributor to handle the Turkish documentation. The distributor knows the market, so the distributor is assumed to take care of it. In practice this is often true: the distributor commissions a translation, attaches it to the product, and the requirement is met in a nominal sense.
 
What the distributor is rarely equipped to do is verify that the translation meets the terminology of the applicable TS EN standards, that the declaration of conformity follows the correct format, that signal words are used consistently, or that maintenance documentation follows the conventions of Turkish technical writing. The distributor's criterion is typically whether the Turkish text reads coherently, not whether it is compliant.
 
The new regulation makes this gap more visible. As in the EU, distributors in Turkey must check that the machine is accompanied by instructions in Turkish before making it available on the market. Turkish documentation is therefore no longer only the manufacturer's concern; it is checked along the supply chain. A manufacturer who does not control it leaves its quality to chance.
 

▮What correct Turkish CE documentation looks like

A correctly prepared Turkish documentation package for machinery begins before translation: with the identification of the applicable legislation and its Turkish implementation, the applicable TS EN standards, and the format requirements for the declaration of conformity under Turkish practice.
 
It continues with translation that uses the terminology of the applicable TS EN standards: not general Turkish, not the translator's preferred renderings, but the normative terms defined in those standards. Signal words are verified against the Turkish adoptions of the standards, the declaration of conformity is formatted to Turkish conventions, and the instructions are reviewed not only for linguistic accuracy but against the content requirements of the Turkish regulation.
 
This is the documentation process a European manufacturer would recognise as correct for their own market, applied to Turkey. It requires a translation partner who knows the Turkish regulatory framework, has access to the applicable standards, and understands the difference between a translation that reads correctly in Turkish and one that functions as regulatory documentation.
 
We have prepared Turkish CE documentation for European manufacturers since 2002: machinery manuals, declarations of conformity, safety documentation and technical files. Examples include a product catalogue for a German manufacturer, translated directly from German into Turkish and typeset, installation and service specifications for wind turbines in Turkey, and documentation for a European manufacturer of personal protective equipment since 2012. If you are preparing Turkish documentation for a CE-marked product, we are happy to discuss the requirements before translation begins.
 
 

▮Frequently Asked Questions

  • Does a CE mark cover Turkey automatically? A CE-marked machine is generally recognised in Turkey without re-certification, because Turkey implements EU machinery legislation through the Makine Emniyeti Yönetmeliği. The documentation that accompanies the machine, however, must be in Turkish.

  • What documents must be translated into Turkish for CE-marked machinery? The instructions for use (kullanım kılavuzu) and the declaration of conformity (uygunluk beyanı) must be in Turkish. The rest of the technical file may remain in the original language, provided it can be made available to market surveillance authorities on request.

  • What changes with Turkey's new Machine Safety Regulation? The version published on 16 October 2026 is aligned with EU Regulation 2023/1230 and, like it, applies from 20 January 2027. References, declaration wording and parts of the terminology change accordingly, and distributors must check that Turkish instructions accompany the machine.

  • Why is a translated declaration of conformity not always compliant? The Turkish declaration of conformity follows a defined format with fixed wording. A declaration translated without reference to that format is often accurate in content but does not match the expected formula, which raises questions at customs or during market surveillance.

  • What is the difference between UYARI and İKAZ in Turkish safety documentation? Both are plausible translations of WARNING, but the Turkish adoptions of the applicable standards use TEHLİKE, UYARI and DİKKAT for DANGER, WARNING and CAUTION. What matters is consistent use throughout the document.

  • What is required for partly completed machinery entering Turkey? Partly completed machinery (kısmen tamamlanmış makine) requires a declaration of incorporation in Turkish instead of a declaration of conformity, together with assembly instructions that enable safe incorporation.