Rules for Processing in Organic Production

The ‘processing’ of products produced in accordance with organic farming methods is an organic farming activity. When it is planned to process the products produced according to organic production rules at an operator in Türkiye; according to Article 6, Principles of Commencement of Organic Farming, of the Turkish Regulation on the Principles and Implementation of Organic Farming published in the Official Gazette No. 27676;

1-a-3) Food businesses must submit a Business Registration Certificate or Business Approval Certificate in accordance with the provisions of the Regulation on Registration and Approval Procedures of Food Businesses published in the Official Gazette dated 17/12/2011 and numbered 28145,

1-a-4) Feed businesses must submit a Business Registration Certificate or Business Approval Certificate in accordance with the provisions of the Feed Hygiene Regulation published in the Official Gazette dated 27/12/2011 and numbered 28155.

Turkish Regulation on the Principles and Implementation of Organic Farming Article 28

(1) According to the principles of processing and packaging of organic products, the following rules shall be observed in the processing and packaging of organic products, together with the provisions of the Veterinary Services, Plant Health, Food and Feed Law No. 5996.

a) Operators or subcontractors producing processed feed or food shall establish and update appropriate procedures based on the systematic definition of critical processing steps. The implementation of the procedures must always guarantee compliance of the processed products with the rules of organic production.

b) Operators or subcontractors, during the processing of organic products, shall take the necessary measures to prevent mixing or contamination with products not in compliance with this Regulation, preserve the organic quality of the product, and provide access to all current registered operations and processed quantities by notifying the authorized body.

c) If the operator processes or stores non-organic products, the activities shall be carried out in a separate place or at a separate time until the entire process is completed. Preventive measures shall be taken to avoid the risk of contamination with unauthorized substances or products. Appropriate hygiene measures shall be applied, their effectiveness monitored, and recorded.

ç) If the operator takes the necessary measures against possible mixing and changes with non-organic products and ensures the identification of organic products, organic and non-organic products may be stored at the same time. The operator shall keep records of harvest days, hours, cycles, and acceptance date and time information of the products and submit them to the authorized body.

d) Additives, processing aids, other substances and components used in food and feed processing, and processing practices such as smoking shall comply with good manufacturing practice principles.

e) In the processing of organic products other than wine; the substances and products listed in Annex-8 of this Regulation on Substances and Products to be Used in the Production of Processed Organic Foods, Yeasts, and Yeast Products, microorganisms and enzyme preparations normally used in food processing, natural flavoring substances and preparations, drinking water and salt, meat and egg stamp colors, legally permitted minerals, vitamins, and amino acids shall be used.

f) The use of ionizing radiation in the processing of organic food, feed, or raw materials is prohibited.

g) Organic products shall be produced without the use of genetically modified organisms or products derived from these organisms.

ğ) Processing methods and extraction techniques that do not cause misunderstandings about the true nature of the product shall be used. Organic foods shall preferably be processed using biological, mechanical, and physical methods.

h) When plant, animal, and aquaculture products produced by organic farming methods and organic raw materials, semi-finished or finished products are packaged, the organic product quality shall not be impaired.

(2) For all substances and materials used in the packaging of organic products, the provisions of the Turkish Food Codex Regulation on Materials and Articles in Contact with Food published in the Official Gazette dated 29/12/2011 and numbered 28157 shall apply.

Regarding organic production and labeling of organic products, the Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 specifies the general framework for processed food production rules in Article 16, while specific principles for organic food and organic feed are set out in Articles 7 and 8.

Important: The production of processed organic foods shall be based on the exclusion of foods containing or consisting of engineered nanomaterials. Organic food and feed shall be processed carefully, preferably using biological, mechanical, and physical methods.

Detailed rules are listed in Regulation (EU) 2018/848 Annex II, Part IV. Important rules are listed below; for more information, please refer to Regulation (EU) 2018/848 Annex II, Part IV.

• Food additives, processing aids and other substances and ingredients
  used for processing food and any processing practice applied, such as
  smoking, shall comply with the principles of good manufacturing
  practice

• Products, substances and techniques that reconstitute properties that are
  lost in the processing and storage of organic food, that correct the results of negligence in the processing of organic food, or that otherwise may be misleading as to the true nature of products intended to be marketed as organic food, shall not be used

• substances and products defined in points Regulation (EU) 1334/2008, Article 3(2)(c) and (d)(i) that have been labelled as natural flavouring substances or natural flavouring preparations in accordance with Articles 16(2), (3), and (4) may be used

• Operators shall keep records of any input used in the food production.
  In case of production of composite products, complete recipes/ formulae showing the quantities of input and output shall be kept available for the competent authority or control body.

In addition; Regulation (EU) 2018/848 Annex II, Part I Plant Production Rules Article 1.13 specifies the applicable rules during the preparation of harvested products in the field and refers to Articles 1.2, 1.3, 1.4, 1.5, and 2.2.3 of Part IV. Accordingly, in field preparations*,

1.2. Operators producing processed food shall establish and update appropriate procedures based on a systematic identification of critical processing steps.
1.3. The application of the procedures referred to in point 1.2 shall ensure
that the produced processed products comply with this Regulation at all times.
1.4. Operators shall comply with and implement the procedures referred to in Article 1.2 and, without prejudice to Regulation (EU) 2018/848, Article 28, shall fulfill the following:
(a) take precautionary measures and keep records of those measures;
(b) implement suitable cleaning measures, monitor their effectiveness and keep records of those operations;
(c) guarantee that non-organic products are not placed on the market with an indication referring to organic production.

1.5. The preparation of processed organic, in-conversion and non-organic
products shall be kept separate from each other in time or space.

2.2.3. Only the products for cleaning and disinfection authorised pursuant to Regulation (EU) 2018/848, Article 24 shall be used for this purpose. Operators shall keep records of the use of these products, including the dates of use, the name of the product, its active substances, and the place of use.

*: According to Regulation (EU) 2018/848, ‘means the operations of preserving or processing of organic or in-conversion products, or any other operation that is carried out on an unprocessed product without altering the initial
product, such as slaughtering, cutting, cleaning or milling, as well as packaging, labelling or alterations made to the labelling relating to organic production.

The United States Department of Agriculture National Organic Program (USDA-NOP) has updated definitions with the SOE (Strengthening Organic Enforcement), effective March 19, 2024, including updates to definitions such as processing/processor.

Handle. To sell, process, or package agricultural products, including but not limited to trading, facilitating sale or trade on behalf of a seller or oneself, importing to the United States, exporting for sale in the United States, combining, aggregating, culling, conditioning, treating, packing, containerizing, repackaging, labeling, storing, receiving, or loading.

Handling operation. Any operation that handles agricultural products, except final retailers of agricultural products that do not process agricultural products.

According to § 205.100(a); except for the exempted operations specified in § 205.101, each processing unit or part of a processing unit that processes agricultural products intended to be sold, labeled, or represented as “100 percent organic,” “organic,” or “made with organic” must be certified under the provisions of USDA-NOP Part E and must comply with all other applicable requirements of the Regulation.

According to § 205.201, except for the exempted operations specified in § 205.101, a handling operation intending to sell, label, or represent agricultural products as “100 percent organic,” “organic,” or “made with organic” must develop an organic processing system plan (OSP) approved by an accredited certifying agent. Please refer to § 205.201 for details on OSP.

§ 205.270 specifies the organic processing requirements.
a) Mechanical or biological methods, including but not limited to cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, distilling, extracting, slaughtering, cutting, fermenting, eviscerating, preserving, dehydrating, freezing, chilling, or otherwise manufacturing, and the packaging, canning, jarring, or otherwise enclosing food in a container may be used to process an organically produced agricultural product for the purpose of retarding spoilage or otherwise preparing the agricultural product for market.

b) Nonagricultural substances allowed under § 205.605 and nonorganically produced agricultural products allowed under § 205.606 may be used.

§ 205.272 sets out the rules for preventing commingling and contamination with prohibited substances.
a) The handler of an organic handling operation must implement measures necessary to prevent the commingling of organic and nonorganic products and protect organic products from contact with prohibited substances.
b) The use or reuse of any bag or container that has been in contact with any substance in such a manner as to compromise the organic integrity of any organically produced product or ingredient placed in those containers, unless such reusable bag or container has been thoroughly cleaned and poses no risk of contact of the organically produced product or ingredient with the substance used.