In order to prevent the risk of contamination from substances not allowed in organic farming originating from non-organic agricultural lands adjacent to organic production areas, it is very important to take necessary measures at the bordering rows of organic land that are at risk of contamination, to preserve the integrity of organic products. Organic farmers take various measures against the risk of contamination caused by neighboring non-organic lands at bordering rows where there is a risk of contamination. The most preferred of these measures are leaving an unplanted/uncultivated area between the neighboring land and the organic land, or not considering the products harvested from the bordering rows as organic products. In organic farming terminology, the unplanted/uncultivated spaces left between the organic and non-organic land are generally called a ‘buffer zone’.
The rules stated in the Regulations regarding buffer zones and their importance are presented below:
Regulation on the Principles and Implementation of Organic Farming, published in the Official Gazette No. 27676, General rules of organic farming Article 5 – (1) a)
‘The operator shall assess the risk of contamination in areas with potential environmental pollution and take the necessary measures. The adequacy of the measures taken shall be determined by the authorized body during inspections,’ it states.
Although the term ‘buffer zone’ is not explicitly mentioned in the Turkish Organic Farming Regulation, it is stated that operators must assess environmental risks and take necessary measures. The adequacy of the measures taken by the operator is decided by the control and certification body. For example, a 1-meter buffer zone left to prevent contamination risk from a neighboring non-organic land may not be considered sufficient by the control and certification body, and the extension of this distance to 3 meters and/or the prohibition of selling products harvested from the bordering rows as organic products, with proof of such sales, may be requested.
In other organic farming regulations, issues regarding buffer zones and consequently preventing contamination risks from prohibited substances to organic products are addressed in more detail.
Concerning organic production and labeling of organic products, the Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 has introduced a new definition, especially concerning contamination prevention measures.
Precautionary measures; pursuant to Regulation (EU) 2018/848, measures that are to be taken by operators at every stage of production, preparation, and distribution to avoid contamination with products or substances that are not
authorised for use in organic production in accordance with this Regulation, and to avoid the commingling of organic products with non-organic products.
Along with this new definition, the European Union Organic Farming Regulation also includes explanatory provisions.
Article 28 Precautionary measures to avoid the presence of non-authorised products and substances
Pursuant to Regulation (EU) 2018/848, In order to avoid contamination with products or substances that are not authorised for use in organic production, operators shall take the following precautionary measures at every stage of production, preparation and distribution:
(a) put in place and maintain measures that are proportionate and appropriate to identify the risks of contamination of organic production and products with non-authorised products or substances, including systematic identification of critical procedural steps;
(b) put in place and maintain measures that are proportionate and appropriate to avoid risks of contamination of organic production and products with non-authorised products or substances;
(c) regularly review and adjust such measures; and
(d) comply with other relevant requirements of this Regulation that ensure the separation of organic, in-conversion and non-organic products.
To further clarify the above points:
implement and maintain proportional and appropriate measures to identify contamination risks,
implement and maintain proportional and appropriate measures to prevent contamination risks,
regularly review and adapt the measures,
are very important for compliance with the rule.
Determining whether there is a contamination risk from the neighboring non-organic land, taking into account important parameters such as the risk of the cultivated product and environmental conditions during this assessment, then taking appropriate measures corresponding to the identified risk and maintaining them, and finally monitoring whether the measures taken are still appropriate and increasing them if necessary, are required.
According to Implementing Regulation (EU) 2021/2119 of 1 December 2021 supplementing Regulation (EU) 2018/848 of the European Parliament and of the Council, which lays down detailed rules on certain records and declarations required from operators and groups of operators, as well as technical means for issuing certificates, another important provision is included on this subject. Accordingly:
Article 2 Records to be kept by operators and groups of operators, 2-b) states that documents must be available verifying that operators and groups of operators have taken proportional and appropriate measures to prevent contamination with products and substances not permitted in organic production and to prevent mixing with non-organic products, pursuant to Regulation (EU) 2018/848.
That is; for example, records proving that products harvested from buffer zones have not been mixed with other organic products and have been sold conventionally are mandatory. The quantity of products harvested from buffer zones must be included in the records of the producer and, if in a group, additionally in the group of operator’s records, and the documents of separate sales must be available in the producer’s file to be submitted to the control body.
United States Department of Agriculture – USDA National Organic Program NOP (=National Organic Program)
Unlike other regulations, it directly defines ‘Buffer zone’ in § 205.2 and clarifies the situation further.
Buffer zone. An area located between a certified production operation or portion of a production operation and an adjacent land area that is not maintained under organic management. A buffer zone must be sufficient in size or other features (e.g., windbreaks or a diversion ditch) to prevent the possibility of unintended contact by prohibited substances applied to adjacent land areas with an area that is part of a certified operation.
In § 205.202 Land requirements ‘c’, Any field or farm parcel from which harvested crops are intended to be sold, labeled, or represented as “organic,” must have distinct, defined boundaries and buffer zones such as runoff diversions to prevent the unintended application of a prohibited substance to the crop or contact with a prohibited substance applied to adjoining land that is not under organic management.
According to the USDA NOP Regulation, operators are also expected to provide detailed information about buffer zones in their organic system plans, which must be submitted together with their applications to the control body. An example can be found at the link below. The information provided in the organic system plan regarding buffer zones will be evaluated by the inspector during the inspection.
https://www.ams.usda.gov/reports/organic-system-plan-template