In the Turkish Organic Farming Regulation, the word “transition” appears 76 times. The situation is similar in other regulations and standards. The reason the term “transition” is used so frequently in these regulations is that the concept holds great importance in many different subjects such as labeling, seed use, beeswax use, dry matter content of rations, etc.
Determining the transition date to organic farming is one of the most critical steps in production planning. Regulations generally define separate transition periods for different product categories such as annual and perennial plants, forage crops, and livestock. Therefore, when preparing a plan that includes certified organic production, the transition date must be carefully organized. If retroactive recognition is not available, the date of signing the contract is generally considered the transition date. However, incorrect planning of this date can result in a significant mistake that may delay the producer’s ability to certify their product as organic by one year.
Before moving on to practical information on determining the transition date, let us recall how the regulations address transition periods:
REGULATION ON THE PRINCIPLES AND IMPLEMENTATION OF ORGANIC FARMING (NO. 27676)
The Turkish Organic Farming Regulation defines the transition process in Article 4 (1)(ğ) as:
“the period from the start of activities in accordance with the provisions of this Regulation until the product is certified as organic.”
Article 7 defines “Procedures related to the transition process” as follows:
- a) Areas, animals, bees, and aquaculture engaged in organic farming activities are placed under the transition process. In plant production, products obtained twelve months after the start of organic farming are considered as products of the transition process. The product of the transition process is marketed with the label “Product in the Organic Farming Transition Process.” However, products obtained from animals in the transition process cannot be marketed as products of the transition process, and expressions suggesting organic farming cannot be used in their advertising and labeling.
b) All the rules in this Regulation apply within the scope of the organic farming transition process.
c) In a farm or production unit where organic farming is partially practiced or is under transition to organic farming, the farmer shall keep organic products, products, and animals in the transition process distinguishable from one another and maintain records demonstrating this distinction.
Article 8 (1)(b) clearly defines the transition period in plant production. Accordingly, for plant products to be considered organic:
a minimum two-year transition process must be applied from the sowing date for annual crops, a minimum two-year period before use as feed for meadows and fodder crops,
and a minimum three-year transition period before the first harvest of organic products for perennial plants other than fodder crops. The most important point to consider in the practical determination of the transition date is the methodology explained here.
According to Article 13 (1)(ç)(4), a transition period is not applied for products collected from nature.
EU ORGANIC FARMING REGULATION (EU) 2018/848
According to Article 3 (6) of the EU Regulation 2018/848, which contains definitions:
“’conversion’ means the transition from non-organic to organic production within a given period, during which the provisions of this Regulation concerning organic production apply;.”
According to Article 10 (4):
Products produced during the conversion period shall not be marketed as organic products or as in-conversion products. However, the following products produced during the conversion period and in compliance with paragraph 1 may be marketed as in-conversion products:
(a) plant reproductive material, provided that a conversion period of at least 12 months has been complied with;
(b) food products of plant origin and feed products of plant origin, provided that the product contains only one agricultural crop ingredient, and provided that a conversion period of at least 12 months before the harvest has been complied with.
According to Annex II, Part I, 1.7.1:
For plants and plant products to be considered as organic products, the production rules laid down in this Regulation shall have been applied with respect to the parcels during a conversion period of at least two years before sowing, or, in the case of grassland or perennial forage, during a period of at least two years before its use as organic feed, or, in the case of perennial crops other than forage, during a period of at least three years before the first harvest of organic products.
UNITED STATES NATIONAL ORGANIC PROGRAM (NOP)
According to 7 CFR §205.202, Any field or farm parcel from which harvested crops are intended to be sold, labeled, or represented as “organic,” must:
(a) Have been managed in accordance with the provisions of §§ 205.203 through 205.206;
(b) Have had no prohibited substances, as listed in § 205.105, applied to it for a period of 3 years immediately preceding harvest of the crop.
Unlike the EU and TR Regulations, the NOP Regulation does not include separate transition periods for different product groups (annual, perennial, forage crops). Nor does it define under what conditions a product in transition can be certified. From this, we can conclude that under the NOP Regulation, it is not possible to label or certify a product as being in the transition period.
DETERMINING THE TRANSITION DATE
After summarizing the details of transition periods under various regulations, we can now illustrate the topic with practical examples.
Before starting, we would like to make a reminder. The matters explained in this article should not be confused with “retroactive recognition” retroactive recognition refers to reducing the two-year pre-sowing or three-year pre-harvest transition periods explained here under certain conditions. In this article, we address the normal transition periods without any shortening. For more detailed information about retroactive recognition, please visit the relevant page.
Examples Regarding the Transition Date
The following examples are based on the assumption that after starting organic farming, the producer carried out all practices in accordance with the relevant regulations and that there were no nonconformities that would negatively affect certification during the mentioned processes.
Let us take an example where we decided to practice organic farming in our fig orchard:
The contract signing date with the CB (Control and Certification Body) is April 20, 2025.
The CB carried out the first inspection in May 2025 and confirmed compliance of the agricultural practices performed after April 20 with the regulations.
Let us assume that the harvest date for the region is August 25, 2025.
Accordingly, the date on which this enterprise is considered to have transitioned to organic farming can be recorded as April 20, 2025.
Of course, it should be remembered that this date may vary depending on the C/A’s internal procedure for determining the transition date and the results of its inspections.
In this case, under TR and EU Regulations, this enterprise may market products harvested after April 20, 2026 as “products in the transition period” and products harvested after April 20, 2028 as “organic products.”
Under the NOP Regulation, products harvested after April 20, 2028 may be marketed as “organic products.”
Certification as a transition product is not possible.
If the date on which this enterprise signed the contract with the C/A were after the harvest date (for example, September 10, 2025), the control body would probably carry out the first inspection in the summer of 2026, and the products would be approved as transition period products starting from the 2027 harvest, and as organic products starting from the 2029 harvest.
Let’s take another example from an enterprise planting corn and wheat:
Let’s assume our producer who plants annual crops carried out the following schedule:
- Wheat sowing date: October 15, 2025
- Date of signing the Organic Production Contract with C/A: January 10, 2026
- Corn sowing date: April 5, 2026
- Inspection date of C/A: May 1, 2026
The inspection results confirm that the practices carried out after January 10, 2026 comply with the EU and TR Regulations.
Since the sowing date is taken as the basis here, only the products sown after January 10, 2027 will be harvested under transition status.
That is, the corn and wheat harvested in 2026 cannot be certified under the organic program.
If the producer includes wheat again in the next year’s production plan, the 2027 wheat will also not be certified, because one full year will not have passed between the transition date (January 10, 2026) and the sowing date of wheat (October 2026).
(Note: Contrary to practical reality — if the producer could sow the wheat after January 10, 2027, then the 2027 harvested wheat could be certified as transition.)
The 2027 harvested corn, however, can be certified as a transition period product, since more than one year has passed between the transition date (January 2026) and the corn sowing date (April 2027).
According to NOP, certification of transition period products for corn and wheat is not applicable.
Products sown after January 10, 2028 can be certified as organic under EU and TR Regulations.
Under NOP, however, only the products harvested after January 10, 2029 (not sown!) can be certified as organic.
Before closing, let’s make one warning:
Since sowing and harvest dates may vary depending on seasonal conditions, this possibility must be considered in organic production planning. Therefore, transition dates to organic farming that are too close to sowing dates for annual crops or harvest dates for perennial crops carry a high risk.