Errors in PRP, Mesotherapy and Ozone Procedures: Patient Rights and Compensation

Harm following a PRP, mesotherapy or ozone procedure does not by itself show that there was a medical error. What is reviewed is the purpose for which the procedure was performed, by whom, under what authorization and with which product, how the patient was informed, and how the problem was managed. The legal conditions of the three procedures cannot be treated as equivalent. For mesotherapy and ozone in particular, the new Regulation on Traditional and Complementary Medicine Practices (GETAT), which entered into force on April 28, 2026, and the current procedure-specific guidelines must be taken into account. [1] [2] [3]

This article is not a treatment recommendation. Its aim is to help a person who has had or is considering one of these procedures understand which information is decisive in a legal assessment.

The true nature of the procedure performed must be determined first

The name used in marketing and the method actually applied are not always the same. A package may be offered as a “youth procedure,” “regenerative therapy” or “natural treatment.” A legal review does not stop at such a name; it looks at what was administered to the body, how it was prepared, the route of application, the purpose, and the authorization of the healthcare facility.

This table is neither a clinical protocol nor a statement that all indications are permitted. That a procedure is regulated in a certain field does not mean that it is effective for every disease or that it may be performed by anyone.

Legal review of PRP procedures

Why does preparation from one’s own blood not remove liability?

PRP generally refers to platelet-rich plasma. That it is autologous, that is, prepared from the person’s own blood, does not remove the need for identity verification, proper preparation, infection control, suitability of the materials used, and follow-up. A statement such as “It is your own blood, there is no risk at all” may become the subject of a claim of misleading information that influenced the patient’s decision.

It is not correct to treat PRP directly as stem cell therapy, or to accept that a mesotherapy certificate automatically authorizes every PRP procedure. The procedure performed must be assessed through its purpose, the product used, the relevant professional authorization and the scope of the facility’s permit. The name of a certificate is not, on its own, an authorization document for all medical procedures. [1] [4]

Which records are reviewed?

The dates of blood collection and preparation, the matching of the product to the patient, the details of the kit used, the area of application, the person who performed the procedure and the record of complaints afterwards are important. If another substance was applied together with PRP, this must be stated separately. The mismatch between the patient’s claim that “only my own blood was to be used” and the records concerning the use of a different product is reviewed in terms of both consent and the contract.

Failure to obtain the expected cosmetic result is not considered a technical error in every case. However, if a specific result was expressly promised, the content of the advertisement, correspondence and contract may change the assessment. Whether the contract is a mandate contract or a contract for work (eser sözleşmesi) cannot be derived merely from the word “aesthetic”; the performance undertaken must be made concrete. [4]

Legal review of mesotherapy procedures

The authorization of the practitioner and of the place are checked together

In mesotherapy, the authority to practice a health profession, the training/certification requirements for the relevant procedure, and the permit of the unit where the procedure is performed are important together. The operating license of a beauty salon does not by itself confer the authority to perform a medical intervention. Likewise, that a facility is authorized for one procedure does not mean that it is authorized for all methods. The new GETAT regulation and the current scope of practice published by the Ministry must be taken as the basis. [1] [2] [3]

The review asks not only whether the document exists but also whether it was valid on the date of the procedure. A certificate obtained afterwards does not automatically cure an earlier authorization problem. Conversely, finding a breach of the permit does not by itself prove that all the claimed damages arose from that breach; causation is assessed separately.

Why are content and product information decisive?

The name of the substance used, its manufacturer, its serial or batch information, its expiry date, its storage conditions and the purpose of application must be established. General expressions such as “vitamin cocktail” may not provide sufficient clarity in a dispute. That a product is on the market for one purpose does not show that it is suitable for every route of application or every indication.

The patient’s pre-existing conditions, the medications the patient uses and the allergies the patient has reported are also part of the assessment. The healthcare facility may argue that necessary information was withheld from it by the patient; in that defense, it must be shown which questions were asked, which answers were received, and how the missing information relates to the harm. The patient’s signature does not entirely remove the facility’s obligation to take a medical history.

Legal review of ozone procedures

Different forms of application may exist under the heading of ozone. The review should not be conducted with the sentence “ozone therapy was performed” without first establishing the name of the method and its records. The authorization of the practitioner concerned, the permitted place, patient selection, the scope of the procedure and the management of the adverse event are separate headings. [1] [2] [3]

Promises such as “cures all diseases,” “you can stop your medications” or “gives definite results” become significant particularly where they led the patient to stop or delay existing treatment. The claim must be supported by the full content of the advertisement, the specific advice given to the patient and the effect of the delay on the health outcome. The 2025 regulation on promotion is also taken into account with regard to misleading presentation of scientific data in the promotion of healthcare services and to treatment claims about methods that are not accepted. [5]

That a procedure was performed at an authorized center does not guarantee its outcome. Conversely, its “complementary” nature does not mean that the required monitoring and medical care may be held to a lower level. The selection of the method for a particular patient and the explanation of alternatives may be the subject of expert review.

How are a complication and a procedural error distinguished?

In a dispute, it is not enough to look only at the photograph of the harm or at the outcome report. The assessment before the procedure, the choice of method, the application and the follow-up are reviewed as a whole. If the patient reported the problem in time but received no answer, or was not referred for the necessary evaluation, this may constitute an independent breach even if the initial procedure was appropriate.

The healthcare facility’s strong defense is that the procedure was carried out in accordance with the relevant standards, that a known risk materialized despite sufficient information, and that it was managed in time. This defense needs to be supported by the procedure records. The patient’s counter-allegation must also be more concrete than “the result is bad”: points such as lack of authorization, a wrong product, an undisclosed additional procedure, delay in follow-up or gaps in the file must be identified.

Under Article 49 of the Turkish Code of Obligations (TBK) and the provisions on contractual liability, damage and an adequate causal link are reviewed separately. A pre-existing disease or a later, separate intervention may affect the outcome. The expert should assess these possibilities with reasons, and should not turn the uncertainty automatically into a definitive conclusion against the patient or against the doctor. [4] [6]

For informed consent, see the article does a consent form relieve the doctor of liability, and for filler and botox procedures, the article faulty Botox and filler applications.

Informing the patient and promises of results

Consent must be obtained before the procedure and in a form the patient can understand. Which method will be applied, the limits of the expected benefit, the significant risks, the alternatives, and what may happen if the procedure is not performed must be explained. Information on the number of sessions and the fee does not replace medical information. It also cannot be assumed that the conditions remain the same for every new session. [2]

As an example, suppose that the patient was told only about PRP but another product was also injected. In such a case, the problem is not merely that the result failed; the scope of the consent and conformity with the agreed performance are also discussed separately. This example is not a real case and is not intended to indicate a particular compensation outcome on its own.

Advertising images, messages, package descriptions and discussions before payment should be preserved. The conditions required for using patient photographs in promotion are separate from treatment consent. A patient’s acceptance of a procedure does not automatically create permission to share the patient’s image on social media. [5]

For similar innovative treatments, see our article on patient rights in stem cell treatments.

Which documents should be collected if harm occurs?

• The dates of all sessions, the identities of the practitioners and the facility information.
• The contract, information and consent documents; product and device records.
• Health findings before and after the procedure and subsequent treatment records.
• Messages in which the complaint was reported and the replies given.
• Invoices, bank receipts (dekont) for payments, and the costs of re-treatment and transportation.
• Documents showing incapacity to work, loss of income and permanent effects.

It is important to preserve the originals of the documents and not to alter their dates and context. If the health problem continues, preparing the legal file should not delay the necessary medical evaluation. Photographic records may be supportive; they do not replace specialist examination and medical measurements.

For obtaining the records, see how to obtain a patient file and medical records, and for proof, see how malpractice is proven.

How are compensation and the route of application determined?

In a relationship with a private facility or an independent physician, consumer law, contract and tort are reviewed; in public healthcare services, service fault and the provisions on administrative jurisdiction are reviewed. In private disputes, the court with subject-matter jurisdiction, the amount of the claim and mediation as a condition precedent to litigation are assessed separately. An application to the Provincial Health Directorate (İl Sağlık Müdürlüğü) or to the patient rights unit is important for supervision, but does not by itself cause compensation to be paid. [4] [7] [8]

The items that may be claimed are treatment expenses connected with the event, loss of working capacity and of earnings, the need for care, and non-pecuniary damage. A refund of the fee may also be assessed separately under the contract. The same damage cannot be claimed to be compensated twice. Whether an expense was necessary and its connection with the procedure must be proven with evidence.

In calculating time limits, whether the procedure was private or public in nature is decisive. While the outcome of a criminal complaint is awaited, it should not be assumed that the time limits for a civil or administrative action are automatically suspended. An older procedure is assessed under the legislation and medical standards in force on the date of the procedure; the 2026 regulation is not automatically applied to past events.

For the general framework of the subject, you can see our page on medical malpractice and physician error cases.

Conclusion

In disputes over PRP, mesotherapy and ozone, the right starting point is not to tie the three procedures to a single rule of authorization or liability. The method of application, the authorization of the person and the place, the nature of the product, and the information and follow-up records should be assessed together. The scope of compensation, in turn, is determined through the breach, the damage and causation.

Frequently Asked Questions

Is a beauty salon license enough to perform these procedures?

An operating license is not the same as authority to perform a medical intervention. The procedure actually performed, the practitioner’s professional authorization and the facility’s relevant permits must be checked separately.

Is PRP stem cell therapy?

These two concepts are not synonymous. In a legal review, the content, the method of preparation and the intended use are taken as the basis, rather than the marketing name given to the product.

I did not get a result; can I ask for a refund of the entire fee?

Mere dissatisfaction does not give rise to a right of refund in every case. The promised performance, a defective service or breach of contract, and a lack of information are assessed separately.

Can an action not be brought against a certified practitioner?

A certificate does not provide immunity from liability. Besides authorization, the appropriateness of the specific procedure, care and causation are reviewed.

Does a complaint to the Provincial Health Directorate stop the compensation time limit?

It cannot be accepted that a supervisory complaint stops all compensation time limits. The time limit must be calculated separately for the relevant application and route of action.

Sources and legal bases

1. Regulation on Traditional and Complementary Medicine Practices, Official Gazette (RG) April 28, 2026, No. 33237. Ministry of Health (Sağlık Bakanlığı) announcement of entry into force and link to the legislation.
2. Patient Rights Regulation, Articles 15–18, 24, 26, 31. Ministry text.
3. Ministry of Health, Department of Traditional, Complementary and Functional Medicine Practices; practice guidelines, authorized centers and practitioner information. Official unit.
4. Law No. 6098, Turkish Code of Obligations, Articles 49–56, 112, 115, 470 et seq., 502 et seq. Official legislation.
5. Regulation on Promotional and Information Activities in Health Services, Official Gazette (RG) November 12, 2025, No. 33075, Articles 5–8. Ministry text.
6. Law No. 6100, Code of Civil Procedure, Articles 190, 266, 281–282. Ministry of Justice legislation record.
7. Law No. 6502 on Consumer Protection, Articles 3, 13–16, 73–73/A. Official legislation.
8. Administrative Procedure Law No. 2577, Articles 7, 13. Ministry of Justice legislation record.