Published in the Official Gazette No. 27676, ‘Turkish Regulation on the Principles and Implementation of Organic Farming, ARTICLE 2 – (1) Scope’:
This Regulation covers the production or supply of all kinds of plant, animal and aquaculture products and inputs to be used in accordance with the organic farming method, yeasts used as food or feed, collection of products from forests and natural areas in compliance with the principles of organic farming, the processing, packaging, labeling, storage, transportation, marketing, control, certification, inspection of these products, as well as technical and administrative issues regarding penal provisions.
In other words, the storage of products produced in accordance with the organic production method and products collected from forests and natural areas in compliance with the principles of organic farming is considered an organic farming activity.
In the same Regulation, Article 4 Definitions includes: ‘Enterprise: A place where organic products are produced, processed, stored and marketed under the control of the authorized body and by concluding a contract with such bodies’. Accordingly, products must be stored not only during the production, processing, and sales stages but also during the ‘storage’ stage, which is an important step of the production chain, in accordance with the principles and rules of organic farming, and this must be controlled by the authorized control body as part of traceability and included in the certification process.
Similarly, in Article 4 Definitions, ‘Organic farming activities: The production or cultivation of organic products or inputs by using soil, water, plants, animals, and natural resources, the collection of products from natural areas and resources, harvesting, slaughtering, processing, classification, packaging, labeling, preservation, storage, transportation, marketing, import, export, and other processes until the product or input reaches the consumer’ is defined.
The area where storage takes place is considered a production unit within the scope of organic farming activities and must be controlled by the authorized control body.
A production unit is also defined in the Turkish Regulation as: ‘The land parcels, pastures, grazing areas, animal shelters, aquaculture production sites and systems, and facilities to be used for storing agricultural products, raw materials and inputs used in production’.
If the operator does not have their own storage and makes an agreement with a storage owner, they must sign a contract with the natural or legal persons who perform storage and similar subcontracted services. Subcontracted storage activity is strictly included in the organic farming control system.
The Turkish Regulation, Article 36 – (1) states: ‘The control procedure includes written documents, plans, ledgers, reports, records, fields, enterprises, and critical control points such as warehouses, as well as observations’. If several units are operated in the same area by the operator, the units and storages where non-organic products are produced are also subject to control procedures.
The Turkish Regulation, Article 42, defines the responsibilities of the operator. Accordingly, the operator must provide the authorized body with all information and documents related to the organic farming activity, notify any changes, and open each unit related to organic production to the authorized body in order to enable the necessary controls at every stage of production. The operator and/or intermediary, trader, storage, processing and similar subcontracted services carried out by natural or legal persons, accept the exchange of information between the authorized bodies in cases where they are controlled by different authorized bodies.
Published in the Official Gazette No. 27676, ‘Turkish Regulation on the Principles and Implementation of Organic Farming, Section Five – Processing, Packaging, Labeling, Storage, Transportation and Marketing of Organic Products’ provides very detailed information about the storage rules of organic products:
Article 28 (c) If the operator processes or stores non-organic products, they shall perform their activities in a separate place or at a separate time until the process is completed. They shall take protective measures to avoid the risk of contamination with unauthorized substances or products. They shall apply appropriate hygiene measures, monitor their effectiveness, and record them.
Article 28 (ç) If the operator takes the necessary precautions against possible mixing and changes with non-organic products and ensures the identification of organic products, they may store organic and non-organic products at the same time. The operator shall keep records of harvest dates, times, periods, and acceptance dates and submit them to the authorized body.
As defined in Article 42 (4) as part of the operator’s responsibility, it is very important to take protective measures to avoid the risk of contamination with unauthorized substances or products in storages, take appropriate hygiene measures, take necessary precautions against possible mixing and changes with non-organic products, monitor the effectiveness of these measures, record them, and submit these records to the authorized control body.
Turkish Regulation, Article 30 – Storage of Organic Products:
(1) The rules regarding the storage of organic products are stated below.
a) Storage areas of organic products shall be arranged in such a way as to allow the identification of the products, prevent mixing or contamination with other products or substances not deemed appropriate by this Regulation, and ensure the identification of batch numbers. Insulating materials and refrigeration equipment used in areas where organic products are stored shall be selected for this purpose. Before and after processing, organic products shall be stored separately from non-organic products either in a different place or at a different time.
b) In cases where separate storage is not possible, the operator shall take measures to prevent mixing of organic products with conventional products. In cases where operators handle both non-organic and organic products, and where they store other agricultural products and foodstuffs in storage facilities:
Organic agricultural products shall be kept separate from other non-organic agricultural products and/or foodstuffs.
All necessary measures shall be taken to prevent mixing or changes with non-organic products and to ensure identification.
Before the storage of organic products, appropriate cleaning measures shall be taken, their effectiveness shall be monitored, and the records shall be kept by the operator.
c) During the storage of organic products, no pesticide or method that may cause the loss of the organic quality of the product shall be used.
ç) In the storage of organic products, no materials or substances that may cause the loss of the organic quality of the product shall be used, and no unnatural practices shall be carried out.
d) Records regarding the storage conditions, as well as the quantities and dates of entry and exit of the stored organic products, shall be kept regularly by the operator. These records, signed by the operator, shall be approved by the authorized body. One copy of the schedule shall be kept by the operator and the other by the authorized body.
e) In organic plant and animal production units, the storage of inputs not permitted by this Regulation is prohibited.
In addition to the above, Article 32 (ğ) on the Marketing of Organic Products states: In case of import, the importer must provide the authorized body with the requested documents in full. For the purpose of re-certification, the authorized body may request information and documents. One of the most important of these is detailed explanatory documents regarding the suitability of the buildings to be used for the storage of imported products.
Regarding organic production and labeling of organic products, Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018; Article 3 Definitions
Defined the stages of production, preparation, and distribution as: ‘any stage from the initial production of an organic product to its storage, processing, transportation, and sale or delivery to the final consumer, including, where relevant, labeling, advertising, import, export, and subcontracting activities’.
According to Regulation (EU) 2018/848 on organic production of the European Union, the main stages of organic production are: Production, Preparation, Distribution, Storage, Import, and Export.
The European Union’s Regulation (EU) 2018/848, Annex III on Collecting, Packaging, Transport, and Storage of Products specifically addresses these issues. Accordingly, Annex III, Article 7 Storage of Products
7.1. Areas for the storage of products shall be managed in such a way as to ensure identification of lots and to avoid any mixing or contamination with products or substances not in compliance with the organic production rules. Organic and in-conversion products shall be clearly identifiable at all times.
7.2. No input products or substances other than those authorised pursuant to Regulation (EU) 2018/848 for use in organic production shall be stored in organic or in-conversion plant and livestock production units.
7.3. Allopathic veterinary medicinal products, including antibiotics, may be stored in agricultural and aquaculture holdings provided that they have
been prescribed by a veterinarian in connection with the treatment referred to in points 1.5.2.2 of Part II and 3.1.4.2(a) of Part III of Annex II, that they are stored in a supervised location and that they are entered in the records referred to in Article 34(5).
7.4. Where operators handle organic, or in-conversion or non-organic products in any combination and the organic or in-conversion products are stored in storage facilities in which also other agricultural products or foodstuffs are stored:
(a) the organic or in-conversion products shall be kept separate from the other agricultural products or foodstuffs;
(b) every measure shall be taken to ensure identification of consignments and to avoid mixtures or exchanges between organic, in-conversion and non-organic products;
(c) suitable cleaning measures, the effectiveness of which has bee checked, shall have been carried out before the storage of organic or in-conversion products and the operators shall keep records of those operations.
7.5. Only the products for cleaning and disinfection authorised pursuant to Regulation (EU) 2018/848 for use in organic production shall be used in storage facilities for that purpose.
Unlike the Turkish Organic Farming Regulation, Regulation (EU) 2018/848, Implementing Regulation (EU) 2021/1165, Annex IV, Part B lists cleaning and disinfection products for buildings and facilities used for plant production, including storage. Annex IV, Part C lists cleaning and disinfection products for processing and storage facilities. However, no listed product has yet been published.
In the Turkish Organic Farming Regulation, currently, Annex 7 on Products Authorized for Cleaning and Disinfection of Tools and Equipment Used in Animal Husbandry Holdings is in place. Products listed in Annex VII of the former European Union Regulation (EC) 889/2008, used for cleaning and disinfection of animal housing, may continue to be used until 31 December 2025.
According to Regulation (EU) 2018/848, Implementing Regulation (EU) 2021/1165, Annex IV, Part D, the following products listed in Annex VII of the former European Union Regulation (EC) No 889/2008, or products containing the following active substances, cannot be used as biocidal products: caustic soda, caustic potash, oxalic acid, natural essences of plants with the exception of linseed oil, lavender oil and peppermint oil, nitric acid, phosporic acid, sodium carbonate, copper sulphate, potassium permanganate, tea seed cake made of natural camelia seed, humic acid, peroxyacetic acids with the exception of peracetic acid.
Please, when planning to carry out cleaning and disinfection in your storages, regardless of under which Regulation you are producing organic products, request approval from your authorized control body for the suitability of the cleaning and disinfection product before use.
According to Regulation (EU) 2018/848, Supplementing Regulation (EU) 2021/1698, Article 9(1): control by the authorized control body is primarily intended to verify that in situations where organic, in-conversion, and non-organic products are collected by operators at the same time, prepared in the same preparation unit, area or facility, stored, or transported to other operators or units, the operations are carried out separately in terms of place or time; appropriate cleaning measures and precautions to prevent substitution of products have been applied; organic and in-conversion products are always identifiable; organic, in-conversion, and non-organic products are kept separate in terms of place or time before and after preparation operations; and traceability of each lot from the fields to the collection centers is ensured, by verifying records, measures, procedures, or arrangements.
In addition, Regulation (EU) 2018/848, Annex II, Part IV on rules for processed food production defines rules that include important points regarding storage:
1.5. The preparation of processed organic, in-conversion and non-organic products shall be kept separate from each other in time or space.
Where organic, in-conversion and non-organic products, in any combination, are prepared or stored in the preparation unit concerned, the operator shall:
a) inform the control body, accordingly.
c) store organic, in-conversion and non-organic products, before and after the operations, separate by place or time from each other.
1.6. 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.
If you are inspected under the USDA-NOP (National Organic Program), please notify your authorized control body of the cleaning agents you plan to use in your storages and request approval. Synthetic substances allowed for use as disinfectants are listed in 7 CFR 205.601(a), National List of Allowed and Prohibited Substances. Substances listed under § 205.601(a) may only be used in organic product operations in accordance with the authorizations in the National List.