In brief
Regardless of age and marital status, workplaces with 100–150 female employees set up a breastfeeding room no more than 250 metres from the workplace; workplaces with more than 150 female employees set up a childcare centre for children aged 0–6. The count includes female employees in all of the employer’s workplaces within the municipal and adjacent area boundaries, plus male employees who have custody of their child or whose child’s mother has died. The centre can be set up jointly, or the obligation can be met by an agreement with an authorised centre.
Which regulation sets the breastfeeding room obligation?
In businesses with a large female workforce, such as garment workshops, weaving plants and wiring harness production, the same question arises at some point in growth plans: at how many female employees does the breastfeeding room obligation begin, and when is a crèche needed? In textile and garment businesses in Bursa and the surrounding provinces, this threshold can be crossed unnoticed when a second workshop opens, because of the combined count.
The rule is set out in the Regulation on the Working Conditions of Pregnant or Breastfeeding Women and on Breastfeeding Rooms and Childcare Centres, issued under Law No. 6331 (Official Gazette 16.08.2013, No. 28737; as amended on 7.9.2019). We covered the part of the regulation on the working conditions of pregnant and breastfeeding employees in our article on pregnant and breastfeeding employees. This article focuses on the facility obligation, that is, the breastfeeding room and the childcare centre. The information is based on the text in force as of November 2026.
What is required at how many female employees?
Article 13 of the regulation sets the thresholds as follows:
| Number of female employees | Obligation | Children accepted | Location |
|---|---|---|---|
| Fewer than 100 | No facility obligation; the right to nursing leave continues | — | — |
| 100–150 | Breastfeeding room | Under one year old | Separate from the workplace, no more than 250 metres from it |
| More than 150 | Childcare centre (crèche) | Aged 0–6; children who have not reached primary school enrolment age | Close to the workplace; if more than 250 metres away, the employer provides transport |
The obligation arises regardless of the employees’ age and marital status. The answer to the question at how many female employees a crèche is required is “more than 150”: a workplace with exactly 150 female employees sets up a breastfeeding room; the centre obligation begins with the 151st female employee. In centres, children aged 0–24 months, 25–48 months and 49 months and over are kept separate.
How is the number of female employees calculated?
Calculating the threshold correctly is as important as the obligation itself. The regulation sets three rules:
- Total of workplaces: The count is based on the total number of female employees in all of the employer’s workplaces within the municipal and adjacent area boundaries (Art. 13/4). Looking at a single building is not enough.
- Male employees: Male employees whose child’s mother has died or who have been granted custody are also included in the count (Art. 13/5).
- No distinction by status: All employees within the scope of Law No. 6331 are counted regardless of their status (Art. 5/4).
Example calculation: A garment business has two workshops within the same municipal boundaries. Workshop A has 95 female employees and workshop B has 58; there is also a male employee whose wife has died and who has custody of his young child.
- Total: 95 + 58 + 1 = 154
- Result: Since this is more than 150, the obligation is not a breastfeeding room but a childcare centre.
Had the workshops been assessed separately, both would have stayed below 100. So monitor the number at business level and at regular intervals; hires and departures can change the threshold quickly.
Breastfeeding room requirements: what does Annex IV require?
The breastfeeding room requirements are listed in Annex IV of the regulation. The same requirements also apply to childcare centres. Before setting one up, turn this list into a checklist:
| Topic | Minimum requirement |
|---|---|
| Location | Cannot be in a basement or in places that do not open directly to the open air; windows receive direct light |
| Space | In rooms where children stay, at least 3 m² of floor area and 8 m³ of air per child; plenty of light |
| Beds | Beds for at least 10% of the number of female employees and male employees with custody, a sufficient number of observation rooms and a breastfeeding area |
| Floor and walls | Floor easy to clean and not harmful to children; walls painted or covered with a washable finish up to a sufficient height |
| Furniture | Plain, simple furniture that does not collect dust; clean, painted cots with adjustable high rails |
| Wet areas | Sufficient toilets and washbasins for mothers and staff; one child bath for every 10 beds; a child washbasin adjoining the bedrooms |
| Food and nappies | Separate area for preparing and storing baby food and for cleaning; a nappy-changing room separate from the bedrooms |
| Health | Medicines and medical supplies in Annex VI kept in a special cabinet; regularly checked by the workplace physician |
On the staffing side, breastfeeding rooms have one female childminder for every 10 children. Rooms and centres are under the medical supervision of the workplace physician; children’s health monitoring and measures against infectious diseases are the responsibility of the physician and the nurse. Children accepted are entered in the register in Annex V.
Childcare centre: setting one up, shared centres and agreements
The regulation lists three ways to meet the childcare centre obligation:
- Setting up your own centre: A centre close to the workplace that meets the Annex IV requirements. If the centre is more than 250 metres away, the employer provides transport.
- Setting up a shared centre: Employers can set up rooms and centres jointly (Art. 13/3). In this case, the employers or their representatives meet at least once a month to take management decisions (Art. 22). This option is practical for employers with neighbouring facilities in the same OIZ (organised industrial zone) or the same industrial area.
- Agreeing with an authorised centre: The obligation can also be met through an agreement with a centre authorised by public bodies (Art. 13/3).
A centre has one childminder for every 20 children; the manager must have a university degree in a field such as pre-school education, child development, psychology or child health. If there is a room, centre or crèche established under its own specific legislation, the obligation is deemed to be fulfilled (Art. 5/4).
Nursing leave and the daily working arrangement
In workplaces with no facility obligation, the rights of a breastfeeding employee continue. Art. 10 of the regulation states that Art. 74 of Labour Law No. 4857 applies to nursing leave: a female employee with a child under one year old is given a total of 1.5 hours of nursing leave per day; the employee decides the times and how many parts it is divided into, and this time counts as working time.
In addition, a pregnant or breastfeeding employee cannot be made to work more than 7.5 hours a day (Art. 9) and is not made to work at night for one year after giving birth (Art. 8). When planning a breastfeeding room, also think about how nursing leave will be used in practice: the further the room is from the production line, the more of the leave is spent travelling.
Implementation steps from an OHS perspective
- Do the count and repeat it monthly; keep the table jointly with human resources.
- Choose the model: breastfeeding room, your own centre, a shared centre or an agreement with an authorised centre.
- Assess the location: basement floors, proximity to noisy areas or areas where chemicals are used, dust and exhaust sources.
- Add it to the emergency plan: the evacuation route, assembly point and responsible person for the area where children are present must be written down separately.
- Plan physician supervision: medicine cabinet checks, children’s health records and infectious disease measures.
- Keep records: the register, staff information and, for a shared centre, the minutes of the monthly meetings.
Common mistakes include: doing the count based on a single building only; using a windowless area partitioned off from a storeroom as the breastfeeding room; not informing employees that the room exists; leaving the medicine cabinet unchecked; and, even where a shared centre has been set up, not recording the monthly meetings between employers. All of these gaps can be prevented with a little planning at the set-up stage.
To consider this together with the employer’s other obligations, see our article on the employer’s OHS obligations; for risks specific to textile businesses, see our textile sector page and our article on OHS in garment workshops. We recommend deciding the location of the room and the emergency arrangements together with your OHS specialist. You can track the dates of physician checks with the OHS calendar.
Frequently Asked Questions
Does a workplace with exactly 150 female employees have to open a crèche?
No. The regulation requires a breastfeeding room for 100–150 female employees and a childcare centre for more than 150. A workplace with exactly 150 female employees sets up a breastfeeding room; the centre obligation arises when the number reaches 151.
Are male employees included in the count?
Generally not; the count is based on female employees. However, male employees whose child’s mother has died or who have been granted custody are added to the count, and their children also benefit from the room and the centre.
If we have more than one workplace, how is the number of female employees calculated?
Female employees in all of the employer’s workplaces within the municipal and adjacent area boundaries are added together. Two workshops that are each below 100 may exceed the threshold in total.
Can the crèche obligation be met by an agreement with an outside crèche?
Yes, but the agreement must be made with a centre authorised by public bodies. The regulation also allows a shared centre to be set up with other employers; in this case, the employers meet at least once a month to take decisions on the management of the centre.
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Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.