In accordance with the ‘Turkish Regulation on the Principles and Implementation of Organic Farming’ published in the Official Gazette No. 27676; the period from the start of activities in accordance with the provisions of Organic Farming until the product is certified as organic is defined as the ‘Conversion Period’.
Throughout the entire process until the product is certified as organic, organic farming rules are applied.
In plant production, products obtained only twelve months after the start of organic farming are considered as conversion products. Conversion products are marketed with the label “Organic farming conversion product”. However, products obtained from animals in the conversion period cannot be marketed as conversion products, and expressions evoking organic farming cannot be used in their advertisements and labels.
According to Article 8-b of the Turkish Organic Farming Regulation; for plant products to be considered organic, a conversion period of at least two years from the sowing date must be applied for annual plants, at least two years before being used as feed for pastures and forage crops, and three years before the first organic harvest for perennial crops other than forage crops.
According to Article 13-4, no conversion period is applied for wild crops. According to Article 22-1/g; the conversion period in organic beekeeping is one year. Beekeeping products are marketed as organic products provided that the provisions of this Regulation are applied for at least one year.
According to Article 8-c of the Turkish Organic Farming Regulation the control and certification body or control body may extend or shorten the conversion period as a result of the examination of the use of the land in previous years, the practices carried out, the general situation in the region and the cultivated products, risk situations, and records and reports of the operator on the subject. If the land to be used for organic farming by the operator is documented with a certificate obtained from official institutions and organizations that inputs other than those listed in Annex-1 and Annex-2 of the Regulation have not been used retroactively for at least three years, the authorized body may shorten the conversion period by a maximum of one year. The conversion period cannot be applied less than 12 months for annual plants and 24 months for perennial plants. (Because, as stated in the paragraph above, at least two years of conversion period must be applied from the sowing date for annual plants, and three years before the first organic harvest for perennial plants).
According to the United States Department of Agriculture National Organic Program (USDA-NOP) § 205.202 Land requirements; unlike other regulations, products can be sold as non-organic until they are certified as organic. If the products are eligible for organic certification under the NOP, they can be sold as organic once the 3-year period is completed. The concept of the retroactive recognition of previous period does not exist in the USDA NOP Regulation.
Regarding organic production and labeling of organic products, Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018, has made very important updates on retroactive recognition of previous period and operators in third countries and the control bodies carrying out their control and certification must fully comply with the new rules. (Unlike under the previous European Union Regulation, control bodies cannot have its own policy on this issue).
According to Regulation (EU) 2018/848 Article 10.3; if the operator provides proof that the land parcels were natural or agricultural areas that, for a period of at least three years, have not been treated with products or substances that are not authorised for use in organic production, the previous period may be retroactively recognized as being part of the conversion period.
(EU) 2021/1698 – Commission Delegated Regulation (EU) 2021/1698 of 13 July 2021 supplementing Regulation (EU) 2018/848 of the European Parliament and of the Council with procedural requirements for the recognition of control authorities and control bodies that are competent to carry out controls on operators and groups of operators certified organic and on organic products in third countries and with rules on their supervision and the controls and other actions to be performed by those control authorities and control bodies, according to Article 24, Before granting retroactive recognition of a previous period as part of the conversion period, the control authority or control body shall ensure that the operator submits the following documents proving that the land parcels were natural or agricultural areas that, for a period of at least 3 years, have not been treated or have not been contaminated with products or substances that are not authorised for use in organic production in accordance with Regulation (EU) 2018/848.
The control body must also carry out a detailed risk analysis based on documentary evidence and in particular taking into account the total area concerned by the request and the agricultural practices carried out on each land parcel concerned during this period.
Before any cultivation measures are taken by the operator, all production units, equipment, means of transport and facilities under the operator’s control, including the land parcels subject to the request for retrospective recognition, shall be physically inspected by the control body to verify the consistency of the information collected. Soil and/or plant samples shall be taken from each land parcel, including those identified as being at risk of contamination. After verification, the inspector shall draw the inspection report and add photographs of the land to the inspection file. Upon completion of the specified steps, the control body shall prepare a final report including the reasons why the previous period can or cannot be recognized retroactively as part of the conversion period. The control body shall immediately inform the European Commission and the accreditation body of any retroactive recognition granted.