Rules for Receiving Organic and In-Conversion Products
European Union Regulation (EU) 2018/848 Annex III ‘Collecting, Packaging, Transport and Storage of Products’ specifically addresses the acceptance/receipt of products. Accordingly, Annex III, Article 5 Acceptance of products:
When an organic or in-conversion product is received, the operator shall, where appropriate, check that the packaging, container or vehicle has been closed and that the necessary indications are present during packaging of the products and their transport to other operators or units. The operator shall cross-check the information on the label with that on the accompanying documents. The results of these verifications explicitly mentioned in the operator’s records.
In order to preserve the integrity of organic or in-conversion products, and to prevent commingling and contamination; it is necessary to comply with the rules specified here, to take all necessary measures by the operator, to monitor the measures taken, and, where necessary, to increase the measures.
Regulation on the Principles and Implementation of Organic Agriculture, published in the Official Gazette No. 27676, Article 31-Transport of Organic Products (1)(ç); states: ‘During the acceptance of products from other enterprises or units, the person accepting the product shall, where deemed necessary, examine the closure or packaging of the package, as well as the appropriateness of the label. After checking the consistency between the label information and the other accompanying documents of the product, the result of the comparison shall be added to the records.’
With regard to the receipt of organic or in-conversion products, which is of great importance, ‘Obligations and actions in the event of suspicion of non-compliance’, (EU)2018/848 Article 27 explains:
If the operator suspects that a product received does not comply with this Regulation, the operator shall:
identify and separate the product concerned;
check whether the suspicion can be substantiated;
not place the product concerned on the market as an organic or
in-conversion product and not use it in organic production, unless
the suspicion can be eliminated;where the suspicion has been substantiated or where it cannot be
eliminated, immediately inform the relevant competent authority, or,
where appropriate, the relevant control authority or control body,
and provide it with available elements, where appropriate;fully cooperate with the relevant competent authority, or, where
appropriate, with the relevant control authority or control body, in
verifying and identifying the reasons for the suspected non-compliance.
Supplementing Regulation (EU)2021/1698, Article 11 explains the control techniques of the control body. The key element defined in paragraph (5) ‘Mass balance verification’ is the nature and quantities of products delivered to units and, where relevant, the composition of the products.
The nature, quantities, and information in the accompanying documents of the organic or in-conversion products received are used in the mass balance calculation, and they are also important to ensure that organic integrity is maintained and to guarantee that there is no commingling or contamination with organic products.
United States Department of Agriculture-USDA National Organic Program NOP (=National Organic Program)
§ 205.201 Organic System Plan (a) states that the operator must develop an organic system plan, and that the organic system plan must meet the requirements for organic production or processing. According to subparagraph (a)(3), the plan must include a description of the monitoring practices and procedures, including their frequency, to be performed and maintained to verify that the plan is effectively implemented. This description must be appropriate to the certified operator’s operations, scope, and complexity, and must include an explanation of monitoring practices and procedures for verifying the organic integrity of suppliers in the supply chain and of agricultural products received/accepted, as well as preventing organic fraud.
In accordance with this article, the control body shall verify, during the inspection, the monitoring practices and procedures described in the organic system plan for verifying the organic integrity of agricultural products received/accepted and for preventing organic fraud.