LEGAL BASIS OF ORGANIC AGRICULTURE IN TÜRKİYE

In our country, organic agricultural activities are carried out under contract with Control bodies authorized in organic farming by Republic of Türkiye Ministry of Agriculture and Forestry, within the scope of the Organic Agriculture Law No. 5262 and the Regulation on the Principles and Implementation of Organic Agriculture published in the Official Gazette No. 27676.

THE LIST OF AUTHORIZED CONTROL BODIES ACCORDING TO OUR NATIONAL LEGISLATION

is available here:

STARTING ORGANIC AGRICULTURE ACCORDING TO THE REGULATION
According to the information compiled from the website of  Republic of Turkiye Ministry of Agriculture and Forestry
the rules for starting organic agriculture are listed below, and information notes have been added for clarification where necessary.
Also see: Regulation on the Principles and Implementation of Organic Agriculture, Article 6 – Rules for Starting Organic Agriculture:

1. a) The operator who wants to engage in organic agricultural activities and is registered in the relevant registry system of the Ministry according to their field of activity, applies to the control and certification body with the following information and documents.
   Information note:
   The ‘Ministry registration systems’ refer to the relevant registry systems established by the Ministry to register enterprises engaged in plant production, animal husbandry, and aquaculture activities. The database created by the Ministry containing land, product, animal production, aquaculture production, and certificate information for organic operators is the Organic Agriculture Information System (OTBIS=Organik Tarım Bilgi Sistemi).

1. Identity information and documents including the name, address, Turkish ID number, and if available, tax number of the operator, and for foreign individuals, their foreign ID number,
2. Information about the location and position of the enterprise,
3. For food businesses, the Business Registration Certificate or Business Approval Certificate in accordance with the Regulation on Registration and Approval Procedures of Food Businesses published in the Official Gazette dated 17/12/2011 and numbered 28145,
4. For feed businesses, the Business Registration Certificate or Business Approval Certificate in accordance with the Feed Hygiene Regulation published in the Official Gazette dated 27/12/2011 and numbered 28155,
5. For aquaculture, the Aquaculture Certificate and/or the Aquaculture Hatchery Certificate.

1. b) The operator who wants to engage in organic agricultural activities signs a contract with the authorized control body they applied to. The operator may carry out organic agricultural activities individually or as part of a producer group. The producer group may conduct organic agriculture under a legal entity. If the operator carries out the organic agriculture activity with a producer group, they must sign a contract with each farmer. In this case, the operator signs a contract with the authorized body on behalf of the producer group. Farmers included in the producer group are considered operators and are recorded with a unique code. The operator also signs contracts with real or legal persons to whom they outsource intermediary trading, storage, processing, and similar services. Enterprises performing contract production are also included in the organic agriculture control system.
2. c) The operator who has signed a contract with the authorized control body and will collect products from forests and natural areas must obtain written permission from the authority that owns or holds the usage rights of these areas before collection.

ç) The operator who will engage in aquaculture must obtain a cultivation permit from the Ministry. Operators who obtain cultivation permits from the Ministry may produce organic aquaculture products. If the operator will produce organic aquaculture products in public areas, they sign a contract with the authorized control body by applying with written permission from the relevant institution.

1. d) The authorized control body may sign a separate contract for each stage of production, or a single contract specifying each activity separately. The authorized control body assigns a code number to the operator, whether acting independently or within a producer group, according to the coding system prepared by the Ministry and communicated to authorized control bodies.
   Information note:
   According to Article 5, General Rules of Organic Agriculture – 1/b; the authorized control body records the information related to the contracted operator in OTBIS within forty-five days and keeps it updated.
   According to Article 43, based on the information and documents that authorized control bodies are obliged to submit;
   Authorized control bodies make all updates in OTBIS and deletions for operators whose contracts are terminated within fifteen days. The provincial directorate where organic farming is carried out takes reports from OTBIS every six months and preserves this information.

In this section, the general rules of Organic Agriculture (Article 5) are listed based on the Regulation on the Principles and Implementation of Organic Agriculture:
(1) The general rules of organic agriculture are as follows:
a) Organic farming methods can be applied throughout the country, provided that the rules specified in this Regulation are followed. The operator evaluates the contamination risk in areas with potential environmental pollution and takes necessary precautions. The adequacy of these precautions is determined during inspections by the authorized body.
b) Organic agricultural activities are carried out based on a contract signed between the operator and the authorized body. This contract represents a written agreement stating that agricultural activities will be conducted in accordance with the provisions of this Regulation. The authorized body registers the operator’s information in OTBIS within forty-five days.
c) Buildings, tools, and equipment used in conventional production may be used in organic production after being cleaned and disinfected.
ç) All stages of organic agricultural activities are recorded to ensure traceability.
d) Food, feed, food additives, plant protection products, fertilizers, soil conditioners, seeds, microorganisms, products used for animal health, and animals that are partially or entirely derived from GMOs, contain GMOs, or consist of GMOs cannot be used in organic farming.
e) Operators who use non-organic products that are not food or feed must ensure that the product supplied by the seller is not produced from GMOs or GMO-derived products, and this must be confirmed with the Seller Declaration included in Annex-12 of the Regulation.
f) Farms that do not produce entirely organic may be divided into clearly separated units or aquaculture areas. In such areas, if livestock is practiced, different species must be present. If aquaculture is practiced, the same species may be present provided there is a physical separation between production areas. In the case of plant production, varieties that are easily distinguishable from one another must be present.
g) If not all parts of a farm are used for organic production, the operator must separate the land used for organic units, the animals and products produced by organic units, from those used or produced by non-organic units, and must keep records showing this separation properly.
ğ) In organic farming, the use of non-renewable resources and off-farm inputs is kept to a minimum.
h) Recycling of plant and animal-origin products and wastes for use as inputs in agricultural activities is ensured.
ı) Local and regional ecological balance must be taken into account in decisions related to organic agricultural production.

Are there official websites of the European Union and the United States about starting organic agriculture?

The European Union’s website on organic agriculture is here. On this page, you can find informative texts on topics such as EU organic policy, organic logo, legislation concerning the organic sector, frequently asked questions, organic control and certification, and exports to EU countries.

USDA NOP – United States National Organic Program
Relevant webpage is here. You can find answers to some of your questions on this page, such as: What is organic? Who is eligible for organic certification? How can I get started? What are the steps toward organic certification?

The USDA NOP training page, which is open to everyone and contains highly valuable educational content on organic production regardless of regulatory scope, can be accessed by registering here . Through this platform, you can receive training and learn about organic farming practices.

Regulation (EU) 2018/848 of the European Union on Organic Production and the USDA NOP (United States National Organic Program) provide more comprehensive information on this subject compared to the Turkish legislation “Regulation on the Principles and Implementation of Organic Agriculture.”
While the Turkish legislation addresses this topic under general rules in Article 5, the other regulations explain the objectives, principles, and rules of organic farming separately and in detail.

Regulation (EU) 2018/848 – Article 4 Objectives:
a) contributing to protection of the environment and the climate;
b) maintaining the long-term fertility of soils;
c) contributing to a high level of biodiversity;
d) substantially contributing to a non-toxic environment;
e) contributing to high animal welfare standards and, in particular, to meeting the species-specific behavioural needs of animals;
f) encouraging short distribution channels and local production in the various areas of the Union;
g) encouraging the preservation of rare and native breeds in danger of extinction;
h) contributing to the development of the supply of plant genetic material adapted to the specific needs and objectives of organic agriculture;
i) contributing to a high level of biodiversity, in particular by using diverse plant genetic material, such as organic heterogeneous material and organic varieties suitable for organic production;
j) fostering the development of organic plant breeding activities in order to contribute to favourable economic perspectives of the organic sector.

The USDA NOP does not contain a regulation article titled “general objectives.”
However, the most emphasized point throughout § 205.200 and the USDA NOP standards Part C is that all production practices must maintain or improve the operator’s natural resources, including soil and water quality.

According to the Organic Foods Production Act of 1990, the objectives of USDA organic regulation are:
(1) Establish national standards governing the marketing of certain agricultural products as organically produced;
(2) Assure consumers that organically produced products meet a consistent standard;
(3) Facilitate interstate commerce in fresh and processed food that is organically produced.

Regulation (EU) 2018/848 – Article 5 General Principles:
Organic production is a sustainable management system that is based on the following general principles:
(a) respect for nature’s systems and cycles and the sustainment and enhancement of the state of the soil, the water and the air, of the health of plants and animals, and of the balance between them;
(b) the preservation of natural landscape elements, such as natural heritage sites;
(c) the responsible use of energy and natural resources, such as water, soil, organic matter and air;
(d) the production of a wide variety of high-quality food and other agricultural and aquaculture products that respond to consumers’ demand for goods that are produced by the use of processes that do not harm the environment, human health, plant health or animal health and welfare;
(e) ensuring the integrity of organic production at all stages of the production, preparation and distribution of food and feed;
(f) the appropriate design and management of biological processes, based on ecological systems and using natural resources which are internal to the management system, using methods that:
i. use living organisms and mechanical production methods;
ii. practice soil-related crop cultivation and land-related livestock production, or practice aquaculture which complies with the principle of the sustainable exploitation of aquatic resources;
iii. exclude the use of GMOs, products produced from GMOs, and products produced by GMOs, other than veterinary medicinal products;
iv. are based on risk assessment and the use of precautionary measures and preventive measures, where appropriate;
(g) the restriction of the use of external inputs; where external inputs are required or the appropriate management practices and methods referred to in point (f) do not exist, the external inputs shall be limited to:
(i) inputs from organic production; in the case of plant reproductive material, priority shall be given to varieties selected for their ability to meet the specific needs and objectives of organic agriculture;
(ii) natural or naturally-derived substances;
(iii) low solubility mineral fertilisers.

In Article 6 of the Regulation on the Principles and Implementation of Organic Agriculture, the “Application Process” for starting organic farming is described.

Within the scope of Regulation (EU) 2018/848 of the European Union, important points regarding the “Application Process” are presented below with references to the relevant articles:

Regulation (EU) 2021/1698 – Article 10(4): The control authority or control body shall not certify operators or groups of operators that have been withdrawn by their previous control authority or control body in the last 2 years, unless the recognition of the previous control authority or control body has been withdrawn by the Commission.

Regulation (EU) 2021/1698 – Article 1(2/e): The translations of the production rules and control measures set out in Regulation (EU) 2018/848 and the delegated and implementing
acts must be made available in an understandable language to operators or group operators who sign a contract with the control body.

Regulation (EU) 2021/1698 – Article 10(1)(b): the operator or group operator must confirm that they have not been certified by another control body in relation to activities carried out in the same third country regarding the same category of products, including in cases in which operators or groups of operators operate at different stages of production, preparation or
distribution.

Regulation (EU) 2021/1698 – Article 10(1)(c): A confirmation must be available that the members of a group of operators have not been certified on an individual basis for the same activity for a given product covered by the certification of the group of operators to which they belong.

Regulation (EU) 2021/1698 – Article 10(3): If the operator or group operator changes the control body, the new control body contacts the previous one, requests the relevant information and documents within 30 days, and evaluates the received information and documents. If the previous control body does not transmit the information or if there are doubts about the provided information, the new control body shall not issue certificates until the doubts are eliminated.

According to the USDA NOP – United States National Organic Program, unlike other regulations, the following are required during the application process:
The Organic System Plan must be submitted along with the application form, and the fee must be paid in accordance with the pricing instructions once the control body’s fee proposal is accepted.

• 205.401 Application for certification
  A person seeking certification of a production or handling operation under this subpart must submit an application for certification to a certifying agent. The application must include the following information:
  (a) An organic production or handling system plan, as required in § 205.201;
  (b) The name of the person completing the application; the applicant’s business name, address, and telephone number; and, when the applicant is a corporation, the name, address, and telephone number of the person authorized to act on the applicant’s behalf;
  (c) The name(s) of any organic certifying agent(s) to which application has previously been made; the year(s) of application; the outcome of the application(s) submission, including, when available, a copy of any notification of noncompliance or denial of certification issued to the applicant for certification; and a description of the actions taken by the applicant to correct the noncompliances noted in the notification of noncompliance, including evidence of such correction; and;
  (d) Other information necessary to determine compliance with the Act and the regulations in this part.

WHICH PRODUCTS CAN BE CERTIFIED ACCORDING TO THE REGULATION YOU ARE CONCERNED WITH, AND CAN YOUR ACTIVITY AND PRODUCTS BE CERTIFIED AS ORGANIC?

In the Turkish legislation “Regulation on the Principles and Implementation of Organic Agriculture,” there is no specific article addressing this topic. However:

According to USDA NOP – United States National Organic Program:
§ 205.100 What can be certified:
Except for exempt operations (see § 205.101), each production or handling operation or a portion of an operation that produces or handles agricultural products intended to be sold, labeled, or represented as “100 percent organic,” “organic,” or “made with organic ingredients” must be certified.

According to Regulation (EU) 2018/848 of the European Union on Organic Production, certifiable products include:

• Agricultural products and
• Products closely linked to agriculture, i.e.: Products listed in Article 2(1) of Regulation (EU) 2018/848 and included in the EU agricultural product CN code list (Annex I of TFEU), and
• Products listed in Annex I of Regulation (EU) 2018/848 as closely related to agriculture.
  If a product does not meet either of these conditions, it cannot be certified.

Annex I of Regulation (EU) 2018/848 – Products closely linked to agriculture:
• Yeasts used as food or feed,
• maté, sweetcorn, vine leaves, palm hearts, hop shoots, and other similar edible parts of plants and products produced therefrom,
• Sea salt and other salts for food and feed,
• silkworm cocoon suitable for reeling,
• Natural gums and resins,
• Beeswax,
• Essential oils,
• cork stoppers of natural cork, not agglomerated, and without any binding substances,
• Cotton, not carded or combed,
• Wool, not carded or combed,
• Raw hides and untreated skins,
• Plant-based traditional herbal preparations.

The definition of “products closely linked to agriculture” is not included in the USDA NOP.
However, unlike other regulations, the USDA NOP defines exempt operations in § 205.101:

• 205.101: The following operations, listed in paragraphs (a) through (h), are exempt from certification under Subpart E and from submitting an organic system plan under § 205.201, but must comply with all applicable requirements in Subpart C (production and handling), Subpart D (labeling), and paragraphs (a) through (i) of this section:
  a – A production or handling operation that sells agricultural products as “organic” but whose gross agricultural income from organic sales totals $5,000 or less annually.
  b – A retail establishment that does not process organically produced agricultural products.
  c – A retail establishment that processes, at the point of final sale, agricultural products certified under this part as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s)).
  d – A handling operation that only handles agricultural products that contain less than 70 percent organic ingredients (as described in § 205.301(d)) or that only identifies organic ingredients on the information panel.
  e – An operation that only receives, stores, and/or prepares for shipment, but does not otherwise handle, organic agricultural products that:
  (1) Are enclosed in sealed, tamper-evident packages or containers prior to being received or acquired by the operation; and
  (2) Remain in the same sealed, tamper-evident packages or containers and are not otherwise handled while in the control of the operation.
  f – An operation that only buys, sells, receives, stores, and/or prepares for shipment, but does not otherwise handle, organic agricultural products already labeled for retail sale that:
  (1) Are enclosed in sealed, tamper-evident packages or containers that are labeled for retail sale prior to being received or acquired by the operation; and
  (2) Remain in the same sealed, tamper-evident packages or containers that are labeled for retail sale and are not otherwise handled while in the control of the operation.
  g – A Customs broker (per 19 CFR 111.1) that only conducts customs business but does not otherwise handle organic agricultural products.
  h – An operation that only arranges for the shipping, storing, transport, or movement of organic agricultural products but does not otherwise handle organic products.

Under which scope do you request control and certification?

According to the Turkish legislation “Regulation on the Principles and Implementation of Organic Agriculture”:

• Plant production,
• Animal production,
• Aquaculture production, and
• The production or supply of inputs suitable for organic farming methods,
• Yeasts used as food or feed,
• Wild collection of products from forests and natural areas in accordance with organic principles,
• Processing, packaging, labeling, storing, transporting, and marketing of these products.
  In the Turkish Regulation, agricultural products are listed separately.

Important note: In the Turkish Regulation, “inputs” included in the scope are not subject to accreditation audits and are instead supervised by Republic of Türkiye Ministry of Agriculture and Forestry.

According to Regulation (EU) 2018/848 of the European Union, the scope is limited by the official list indicating CN codes of the Union:

• live or unprocessed agricultural products, including seeds and other plant reproductive material,
• processed agricultural products for use as food,
• feed.

According to USDA NOP – United States National Organic Program, scopes include:
Crop: Plant products
Livestock: Animal husbandry
Processed products: Processed agricultural products
Wild crops: Wild-collected products

Important note: On March 11, 2024, the USDA Agricultural Marketing Service (AMS) issued a proposal to amend the USDA organic regulations. The proposal aims to establish specific standards for organic mushroom production and organic pet food processing, providing more consistent standards for these markets.
The rules for these products will take effect as of February 22, 2027.
No new product category is expected to be added. These products will be defined within the existing categories, and control body personnel will need to be trained and equipped accordingly.

Which product categories do you request control and certification for?

According to the Turkish legislation “Regulation on the Principles and Implementation of Organic Agriculture”:

• Plant production
• Animal production
• Aquaculture production
• Processing, packaging, labeling, storing, transporting, and marketing of organic products
• Fertilizers, soil improvers, nutrients, and plant protection products (not under accreditation scope)

According to Regulation (EU) 2018/848 of the European Union:
The Implementing Regulation (EU) 2021/1378 adopted under Regulation (EU) 2018/848 defines the following product categories in Annex II:
A: Unprocessed plants and plant products, including seeds and other plant reproductive materials;
B: Livestock and unprocessed livestock products;
C: Algae and unprocessed aquaculture products;
D: Processed agricultural products intended for use as food, including aquaculture products;
E: Feed;
F: Wine;
G: Other products listed in Annex I to Regulation (EU) 2018/848 or not covered by the previous categories.

According to USDA NOP – United States National Organic Program:
There is no concept of product category; everything is addressed under the term “scope.”

WHAT SHOULD WE CONSIDER WHEN CHOOSING A CONTROL BODY?

Under Turkish and European Union Regulation, control bodies must be accredited according to TS EN ISO/IEC 17065 standards by the Turkish Accreditation Agency or by internationally valid accreditation institutions recognized through the European Cooperation for Accreditation’s mutual recognition agreement. These accreditation documents must be published and kept up to date on the websites of control and certification bodies. From these documents, you can examine which regulation, scopes, and product categories the control and certification body is accredited for.

Additionally, by reviewing the work permits published on their websites and the lists of authorized control and certification bodies maintained by Republic of Türkiye Ministry of Agriculture and Forestry, you can determine which product scopes the body is authorized for under Turkish legislation.

According to the USDA NOP – United States National Organic Program:
Through the web-based reporting tool “Organic Integrity Database (OID),” which was developed for data submission and the completion of organic activity certifications, you can access information on which countries and product scopes a control body is authorized to operateby clicking here:

A Common Mistake When Choosing a Control Body!
Some operators, thinking “I’ll only sell my product within Türkiye,” may contract with a control body accredited only under Turkish Organic Agriculture Legislation. However, if the product buyer intends to export to the EU or the USA, this can lead to significant issues.

WHEN I DECIDE TO ENGAGE IN ORGANIC PRODUCTION, HOW CAN I ACCESS THE LISTS OF APPROVED OR PROHIBITED PLANT PROTECTION PRODUCTS AND FERTILIZERS ACCORDING TO THE REGULATIONS?

According to the Turkish legislation “Regulation on the Principles and Implementation of Organic Agriculture”:
You can access the regulation here,  and refer to Annexes 1 to 9 for the relevant lists.

According to Regulation (EU) 2018/848 of the European Union:
Commission Implementing Regulation (EU) 2021/1165 of 15 July 2021 authorising certain products and substances for use in organic production and establishing their list.

Under the USDA NOP – United States National Organic Program:
Visit here  for § 205.600 – Criteria for evaluating allowed and prohibited substances, methods, and ingredients.
Unlike other regulations, the USDA NOP lists both allowed and prohibited substances, methods, and ingredients under § 205.600 and in §§ 205.601–205.606.

ONCE I DECIDE TO ENGAGE IN ORGANIC PRODUCTION AND APPLY TO A CONTROL BODY, CAN I BE CERTIFIED AS ORGANIC IMMEDIATELY?

As a reminder, the organic farming control and certification process includes several stages: submission of the application to the control body, review of the application, implementation of the inspection, reporting of the inspection by the inspector, assessment of the inspection report by the certifier, resolution of any sanctions or non-compliances, and certification under suitable conditions. Maintaining compliance with organic farming rules is required for the continuation of certification. This process takes a certain amount of time depending on the regulation, scope, activities, and product categories for which certification is requested. The control body you work with will provide you with information accordingly.

Additionally, if you are producing organically at the land stage, regulations provide for specific transition periods for the land and products, during which all organic rules must still be followed.

According to the Turkish legislation “Regulation on the Principles and Implementation of Organic Agriculture”:

• Article 7-1/a: Areas, animals, bees, and aquaculture involved in organic farming are subject to a conversion period. Products obtained 12 months after starting organic plant production are considered in conversion products and must be labeled as “Organic agriculture in conversion product.” However, products from animals in conversion cannot be marketed as in conversion products, nor can labeling or advertising contain references to organic farming.
• Article 8-1/b: For annual plants, at least two years must pass from sowing; for pastures and forage crops, at least two years before use; and for other perennial plants, a three-year conversion period must be completed before the first organic harvest.
• Article 8-1/c: The control body may shorten or extend the conversion period based on past land use, practices, general regional conditions, crops grown, risk factors, and records. If official documentation proves that non-compliant inputs have not been used for at least the past three years, the conversion period may be shortened by up to one year but can never be less than 12 months for annual or 24 months for perennial crops.
• Article 13-4: No conversion period is applied for wild-collected products.
• Article 16-1/ğ: In animal production:
  1. Meat production: 12 months for cattle, 6 months for sheep/goats/pigs. For animals culled from organic dairy herds, the period is 3/4 of their lifespan.
  2. Milk production: 6 months.
  3. Poultry for meat: 10 weeks if younger than 3 days at start. For egg-laying: 6 weeks.
• Article 22-1/g: Organic beekeeping requires a 1-year conversion period. Products can be marketed as organic if regulations have been followed for at least one year.

Under Regulation (EU) 2018/848 – EU Organic Regulation:

• Article 10: Producers must follow a conversion process, which begins no earlier than the date they notify the control body of their activity.
• Article 10(3): If the operator provides proof that the land was natural or agricultural and untreated with prohibited substances, the prior period can be retroactively recognized as part of the conversion.
• Regulation (EU) 2021/1698 – Article 24: Operators requesting retroactive recognition of a previous period as part of the conversion period must submit a specific application form and required attachments before beginning cultivation.
  Key points include:
  • Each farmer in a group of operator must submit the mentioned application form individually.
  • A detailed risk analysis is conducted based on documentation, parcel history, and practices.
  • Soil and/or plant samples are taken from each land parcel in line with the results of the risk analysis.
  • The inspector draw up an inspection report including photos.
  • The control body draws up a final written report, which must be reported immediately to the European Commission and accreditation body.

Under the USDA NOP – United States National Organic Program:
There is no defined “retroactive recognition of a previous period” process.

• 205.202 Land Requirements:
  To sell, label, or represent products as “organic”:

• Compliance with §§ 205.203–205.206 is required.
• No prohibited substances may have been applied to the land for 3 years prior to harvest.
• There must be clearly defined boundaries and buffer zones to prevent contamination.
  During the transition, no prohibited substances may be used. Categories such as C1 or C2 do not exist. Products may be sold as conventional until the 3-year period is completed.

I WANT TO PRACTICE ORGANIC FARMING AS A GROUP, NOT INDIVIDUALLY. WHAT SHOULD I PAY ATTENTION TO DURING THE APPLICATION STAGE?

According to the Turkish Regulation on Organic Agriculture:

• Article 6-1/b: Operators may engage in organic farming individually or as part of a producer group, which must be established under a legal entity. Each producer in the group must sign an individual contract. The operator contracts with the authorized control body on behalf of the group. Each farmer is assigned a code and recorded. Subcontracted services must also be contracted and included in the control system. The procedures for group formation are to be regulated by a ministerial communiqué.
• Article 39-1/a: One inspector may inspect up to four individual operators per day, or six in the case of producer groups.
  Turkish legislation does not implement an Internal Control System (ICS). All producers within the group must be 100% inspected by the certification body.

According to EU Regulation 2018/848:
Producer group certification has been updated. An ICS system is now implemented (unlike the Turkish model).

• Article 36:
  • Each group of operators shall only be composed of members who are farmers or operators who in addition may be engaged in processing, preparation or placing on the market of food or feed.
  • Individual members must meet criteria related to revenue or land area (e.g., annual turnover of organic production is not more than EUR 25 000 or who have each holdings of maximum).
• EU 2021/279 Article 4: Max group size is 2,000 members.
• Article 9 – EU 2021/1698: At least 5% (min. 10 members) of the group must be inspected annually by the control body.
  ICS staff are subject to witness audits.

Under the USDA NOP:

• § 205.201(c): Group Organic System Plans must describe the Internal Control System, including traceability and mass balance controls.
• § 205.400(g)(8): Internal inspections must be conducted annually with the member present.
• § 205.403(a)(2):
  • Assess the internal control system’s compliance, or ability to comply, with the requirements of § 205.400(g)(8).
  • Conduct witness audits of internal control system inspectors performing inspections of the producer group operation.
  • Either √1.4 or 2% of members (whichever is higher) must be individually inspected.
  • At least one producer group member in each producer group production unit must be inspected.
  • Inspect each handling facility.

I WAS PREVIOUSLY INSPECTED BY ANOTHER CONTROL BODY. I WANT TO SWITCH TO A DIFFERENT ONE.

Turkish, EU, and USDA NOP organic regulations define specific conditions for changing control bodies. Your current and new control body will inform you about legal requirements and additional steps. You may also consult content on our website dedicated to this topic.

Critical information – Turkish Regulation:
When a new certification request is made, proof from the Ministry of Agriculture’s information system (TBS=Tarım Bilgi Sistemi) that the previous operator and related parcels have been deleted must be provided.

USDA NOP – § 205.401(c):
The new application must include:

• Names of previous certifiers and years applied,
• Outcome of applications,
• Copies of any noncompliance or denial notices,
• Description and evidence of corrective actions taken.

EU Regulation 2021/1698:

• Article 10(3): The new control body contacts the previous one within 30 days. If information is not trnsmitted or is doubtful, certification is not granted until doubts are eliminated.
• Article 10(4): If certification was withdrawn by the previous control body in the past two years, the applicant cannot be certified.

WHAT SHOULD I KNOW ABOUT SEEDS AND OTHER PROPAGATION MATERIALS AT THE INITIAL STAGE?

According to organic farming regulations, only organic propagation materials should be used for plant production. However, under certain conditions, untreated conventional materials may be approved by the control body. Use of conventional seedlings is strictly prohibited.

Critical points:

• Organic propagation materials must be prioritized and suitable for organic agriculture.
• Unavailability in sufficient quality or quantity must be justified.
• Permission for use of conventional materials must be obtained before planting.
• Permission is granted for one season and per individual user.
• Under EU rules, derogations for conventional propagation materials will expire on December 31, 2036.