Article 36-Control Operation (1) (ç-d-e) of the Turkish Regulation on the Principles and Implementation of Organic Farming, published in the Official Gazette No. 27676, contains provisions regarding sample collection. Accordingly:
Control bodies authorized to carry out inspections shall:
ç) Take samples for analysis to detect the use of products not permitted for organic production, to detect production techniques that are not in compliance with organic production rules, and to detect possible contamination with products not permitted for organic production. The annual number of samples taken for analysis shall cover at least 5% of the number of operators under the control of the authorized body. The selection of where the samples are taken from shall be based on the overall assessment of the risk of non-compliance with organic production rules at all stages of the organic farming activity. This overall assessment shall take into account all stages such as production, preparation and distribution.
d) Take and analyze as many samples as deemed necessary in any case of suspicion regarding the use of techniques or products not permitted for organic production.
e) Have product samples analyzed in laboratories accredited according to the TS EN ISO/IEC 17025 standard.
The continuity of the laboratory’s accreditation is important and must be monitored. The validity of the laboratory’s accreditation, and the parameters for which it is accredited, can be checked through its accreditation certificates. The control of accreditation certificates can be carried out on the website of the accreditation body from which the laboratory has been accredited, using the laboratory’s accreditation number; for example, for TÜRKAK, “accredited body search”; https://asist.turkak.org.tr/tr/accreditation/accreditationagencysearch
In order to ensure compliance with the relevant requirements specified in TS EN ISO/IEC 17065 (Conformity assessment – Requirements for bodies certifying products, processes and services) Article 6.2.2.2, laboratories providing services must not have any interests that could compromise their impartiality in relation to the production of organic agricultural products.
According to the United States Department of Agriculture-USDA National Organic Program (NOP), unlike other regulations, in order to ensure the reliability of the results, the cost of analysis is borne by the control and certification body.
Regulation (EU) 2018/848, supplementing Regulation (EU) 2021/1698, Annex IV, Part B lists non-compliances that will be considered ‘critical,’ and refusal by the operator to allow sampling by the control body is included in this list.
Sampling, Methods Used for Sampling, and Laboratory Selection for Sample Analysis are described in supplementing Regulation (EU) 2021/1698, Article 12 as follows:
The control authority or control body shall take and analyse samples for detecting the use of non-authorised products and substances for organic production, for checking production techniques not in compliance with the organic production rules or for detecting possible contamination by non-authorised products and substances for organic production.
The control authority or control body shall carry out sampling on at least 5 % of the number of individual operators under its control. For a group of operators, the control authority or control body carry out sampling on at least 2 % of the members of each group.
The selection of the operators and groups of operators where samples have to be taken shall be based on risk assessment including the likelihood of non-compliance with the organic production rules, taking into account all stages of production, preparation and distribution.
In addition to the minimum sampling rate set in paragraph 2, the control authority or control body shall take and analyse samples in each case where the use of non-authorised products and substances or techniques for organic production is suspected, unless the control authority or control body considers that sufficient evidence is available without sampling.
For high-risk products referred to in Article 8 of Regulation (EU) 2021/1698, the control body shall take, in addition to the sampling rate
set in paragraphs 2 and 3 of this Article, at least one field sample of the
crop each year. That sample shall be taken from crops in the field, at the
most appropriate moment to detect potential use of non-authorised
substances according to the assessment of the control authority or
control body. For operators not growing crops, a relevant sample of
incoming raw material or intermediate product or processed product
shall be taken.The control body shall ensure that the laboratories used comply with the following:
(a) they are accredited laboratories that meet the applicable requirements of ISO standard ISO/IEC 17025 on ‘General requirements for the competence of testing and calibration laboratories’;
(b) their accreditation bodies are signatory of the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement;
(c) they have sufficient capacity for analysis and testing and they can ensure that samples are always tested with relevant methods included in the scope of their accreditation;
(d) as regards residue pesticide testing, they are accredited for gas and liquid spectrometry in order to be able to cover the list of pesticide residues monitored under the coordinated multi-annual control programme of the Union set out in Commission Implementing Regulation (EU) 2019/533.
The control authority or control body may delegate sampling tasks to other control authorities or control bodies recognised by the Commission or bodies accredited in accordance with ISO standard ISO/IEC 17025 on ‘General requirements for the competence of testing and calibration laboratories’
According to the United States Department of Agriculture-USDA National Organic Program (NOP), information on sampling and laboratories is provided in § 205.670 of the Regulation and in guidance documents 2610 and 2611. In summary:
Analyses must be carried out in an accredited laboratory; chemical analysis must comply with the most recent edition of the Official Methods of Analysis of AOAC International or other valid methodologies for detecting contaminants in agricultural products. In accordance with NOP 2611; laboratories must have current accreditation under one of the following: –ISO/IEC 17025:2005, General requirements for the competence of testing and calibration laboratories, or an alternative standard approved by USDA NOP on a case-by-case basis.
Sampling must be conducted by an inspector representing the USDA administration or a controller representing the control body, and the costs are borne by the organization that collects the sample.
The controlbody must annually sample and analyze at least five percent of the operators it certifies. A certification body certifying fewer than thirty operators per year must take and analyze at least one operator’s sample annually.
All results of analyses performed shall be made publicly accessible unless the test is part of an ongoing non-compliance investigation.