2.1.6-tr,e SKP Tuerkey TR Part I IMO-Control QA3206 · QA3206 2.1.6 -tr,e SKP Turkey Version: ......

IMO-Control 2.1.6-tr,e SKP Tuerkey TR Part I

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QA3206 2.1.6-tr,e SKP Turkey Version: 21.09.15 IMO Released by: Ruçhan, Şirin Seite: 20 (44)

1. Principle .............................................................................................................................................. 21 1.0 Definition ...................................................................................................................................... 21 1.1 Application .................................................................................................................................... 21 1.2 Impartiality .................................................................................................................................... 23 1.3 Confidentially ................................................................................................................................ 23 1.4 Quality Management .................................................................................................................... 23 1.5 Costs and Services ...................................................................................................................... 24

2. Application for certification ................................................................................................................... 24 2.1 Information on the procedure ........................................................................................................ 24 2.2 Application .................................................................................................................................... 24 2.3 Review of Application ................................................................................................................... 24 2.4 Design of budget and prepayment ................................................................................................ 24 2.5 Inspection Contract and Description of Operator .......................................................................... 25

3. Preparation for inspection (Preparation for evaluation) ........................................................................ 25 3.1 Inspection planning ...................................................................................................................... 25 3.2 Assigning inspectors..................................................................................................................... 26

4. Inspections (Evaluation) ...................................................................................................................... 26 4.1 Definition ...................................................................................................................................... 26 4.2 Execution of inspection ................................................................................................................. 26

4.2.1 Basics ................................................................................................................................... 26 4.2.2 Process of inspection ............................................................................................................ 27 4.2.3 Inspection report.................................................................................................................... 27 4.2.4 Summary Assessment Report (Evaluation Report) ................................................................ 28 4.2.5 100% inspection of small holder groups (IMO II 25.xx): ......................................................... 27 4.2.6 Individual producers (IMO II 04.xx): ....................................................................................... 27 4.2.7 Processors and Exporters (IMO II 10.xx)-including yeast and feed production: ..................... 28 4.2.8 Wild Collection (IMO II 15.xx): ............................................................................................... 28 4.2.9 Beekeeping (IMO II 17.xx): .................................................................................................... 29 4.2.10 Aquaculture (IMO II 20.xx): .................................................................................................... 29 4.2.1 Animal Husbandry ................................................................................................................. 30 4.2.2 Group Certification with ICS .................................................................................................. 30

4.3 Review ......................................................................................................................................... 32 5. Desicion on certification (Certification) ................................................................................................. 32

5.1 Certification procedure ................................................................................................................. 32 5.2 Non-compliances .......................................................................................................................... 32 5.3 Denial of certification .................................................................................................................... 33 5.4 Responsibilities of operator .......................................................................................................... 33

6. Surveillance (Continuation of certification) ........................................................................................... 33 6.1 Communication ............................................................................................................................ 33 6.2 Follow-up inspections ................................................................................................................... 33 6.3 Changes affecting certification ...................................................................................................... 34 6.4 Decision about renewal of certification ......................................................................................... 34 6.5 Decision about scope amendment of certification ......................................................................... 34 6.6 Withdrawal of certification (termination, reduction, suspension or withdrawal) .............................. 34 6.7 Unannounced visits and spot-check inspections ........................................................................... 35

6.7.1 Annual spot-check frequency ................................................................................................ 35 6.7.2 Risk analyze .......................................................................................................................... 36

6.8 Sampling ...................................................................................................................................... 36 6.9 Cases of suspicion and complaints............................................................................................... 36

7. Use of licenses, certificates and marks of conformity........................................................................... 36 7.1 IMO-Logo ..................................................................................................................................... 36 7.2 Private Labels............................................................................................................................... 37

8. Appeals, Complaints and Disputes ...................................................................................................... 37 8.1 Complaints ................................................................................................................................... 37


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8.2 Appeals ........................................................................................................................................ 37 8.2.1 Standard procedure ............................................................................................................... 37 8.2.2 Cancellation of contracts ....................................................................................................... 37

1. Principle

1.0 Definition The terms „control“ and „inspection“ are used synonymously. It is same with „controller“ and „inspec-tor“, just like „control report“ and „inspection report“. Operator in this profile means real person or companies who have applied for certification to deal with organic production, processing (including storages), trading (including middlemens- exemption of chain markets or organic sales points which do not trade organic products with own brands) and taken responsibility to obey rules of laws, regulations and standards by signing contact with an au-thorized inspection and certification body.

1.1 Application IMO-CONTROL Sertifikasyon Tic. Ltd. Şti. carries out inspections for organic production, processing and trading/ export according to Article 28 of Regulation (EC) No. 834/2007 as well as according to the Turkish Organic Regulation (Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik). In this content, IMO-CONTROL is approved by Turkish Ministry of Food, Agriculture and Livestock (lo-cated in Ankara) and EU Commission as a private inspection and certification body for inspection and certification of organic products in Turkey and the other authorized countries. Thence, all in-spection and certification activities of IMO-CONTROL Ltd. Şti. is continously audited by the respon-sible authority, Turkish Ministry of Food, Agriculture and Livestock and thereto EU Commission. IMO-CONTROL Ltd. Şti. developed this standard control programme (SKP) based on the the IMO Organic Standard equivalent to EU Regulation (EG) 834/07 and implementation rules EU Regula-tion (EG) 889/2008 as well as the Turkish Organic Regulation (Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik) to describe control procedures of organic production (agricultural production, wild collection, mushroom production, animal husbandry, beekeeping), processing (pro-cessed products, yeast), trade/export, import, feeding mill and aquaculture production activities. It aims to guarantee an objective and competent evalution of organic products on all production and trading steps. In this sense the standard control programme describes itself as element of the quali-ty management for organic products based on the regulations mentioned above and ISO/IEC 17065. We underline that all operators dealing with organic production, processing, storage and trade (ex-ports/imports/trade) are subject to inspection and certification even they are in a defined project (such as subcontractors/middlemen). In specific conditions different operators (such as tea farmers and a tea processing plant) are combined in a certification project.

2.2.1 Turkish Organic Regulation “Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönet-melik”

IMO-CONTROL Ltd. Şti. carries out inspections and certification for organic production, processing and trading in Turkey based on authorization by Turkish Ministry of Food, Agriculture and Livestock Ministry. All operators located in Turkey and handling organic products shall operate compliant to Turkish Organic Regulation without taking target market into consideration. IMO-CONTROL Ltd. Şti., is authorised to carry out inspection and certification according to Turkish Organic Regulation in following scopes. -organic agricultural production (including organic mushroom production and wild collection);


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-organic animal husbandry (including organic beekeeing); -processing, packing, labelling, storage, transporation and marketing of organic products; -inputs to be used as fertiliser, soil conditioner, nutrient and plant protection.

2.2.2 IMO Organic Standard equivalent to EU Regulation No 834/2007 and implementation rules EU Regulation No 889/2008

IMO-CONTROL Ltd. Şti. carries out inspections and certification for organic production, processing and trading in 3rd countries (countries outside EU) based on authorization by European Commission. As EU Regulation No 834/2007 and implementation rules EU Regulation No 889/2008 are regula-tions applicable to EU countries, IMO has built standards and control measures equivalent to these regulations. For inspection and certification of operators in 3rd countries, IMO-CONTROL Ltd. Şti. carries out inspections and certification based on IMO Organic Standard equivalent to EU Regula-tion No 834/2007 and implementation rules EU Regulation No 889/2008 and EU Regulation No 1235/2008 which regulates imports from 3rd countries. IMO Organic standard is public on www.imoturkiye.com, tab “Yönetmelikler”. IMO-CONTROL Ltd. Şti. Is authorized for inspection and certification of organic handling in below countries and scopes (see also EU Regulation No 644/2014). Turkey; unprocessed plant products, live animals or unprocessed animal products, processed agricultural products for use as food and processed agricultural products for use as feed Afghanistan; unprocessed plant products and processed agricultural products for use as food Azerbaijan; unprocessed plant products and processed agricultural products for use as food Georgia; unprocessed plant products Kazakhstan; unprocessed plant products and processed agricultural products for use as feed Kyrgyz Republic; unprocessed plant products and processed agricultural products for use as food Russia; unprocessed plant products and processed agricultural products for use as feed Tajikistan; unprocessed plant products and processed agricultural products for use as food Turkmenistan; unprocessed plant products and processed agricultural products for use as food Ukraine; unprocessed plant products, processed agricultural products for use as food, processed agricultural products for use as feed Uzbekistan; unprocessed plant products and processed agricultural products for use as food United Arab Emirates; processed agricultural products for use as feed

2.2.3 USDA National Organic Programme (NOP) According to NOP Regulation, operators who produce, process and export/trade “organic”, “100% organic” and “made with organic” products to USA shall be inspected and certified by an accredited body. IMO-CONTROL Ltd. Şti. can offer NOP(National Organic Program) certification with its partner IMOswiss AG (Switzerland), accredited by USDA. Inspections are done by IMO-CONTROL while IMOswiss AG does certification.

2.2.4 JAS (Japanese Agricultural Standard) Yönetmeliği According to JAS Regulation, operators who produce, process and export/trade organic products to Japan shall be inspected and certified by an accredited body.


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IMO-CONTROL Ltd. Şti. can offer JAS certification with its partner IMOswiss AG (Switzerland), accredited by MAFF. Inspections are done by IMO-CONTROL while IMOswiss AG does certification.

2.2.5 Other Standards On request and based on special agreements, inspections on other certification standards (private or governmental) is possible. If private label certification (such as Bio Suisse, Demeter, Naturland, etc.) is requested, IMO shall be informed and operators shall accept inspection results to be handed to these private organisations for recertification.

1.2 Impartiality The service of IMO-CONTROL Ltd. Şti. is accessible to all applicants. IMO-CONTROL Ltd. Şti. re-serves the right to refuse applications in case there is not enough personnel and requested scope is not in authorization and accreditation scope of IMO. To ensure its impartiality, IMO-CONTROL Ltd. Şti. does not offer consultancy service to its appli-cants and does not provide consultancy and advices those conflict its certification. Besides these, information flow essential for inspection and certification activities (such as preparement for inspec-tions, description of nonconformities or explanations on certification standards) are kept at highest level.

1.3 Confidentially To ensure its confidentially, IMO-CONTROL Ltd. Şti. treats all information gained/produced during inspection and certification activities, other sources (such as compliants or authorities) as confiden-tial. With all its employees, meets the following requirements (also see IMO I 1.6): IMO-CONTROL Ltd. Şti. with all employees are committed to maintain absolute confidentiality of

information collected throughout the inspection and certification process. Transmission of datas to third parties is only allowed with agreement of the operator itself. Reserved is the transmission of datas prescribed by law to the competent authority.

For certified operators by IMO-CONTROL Ltd. Şti. in principle no consulting activities are of-fered.

IMO-CONTROL Ltd. Şti. with all their employee behave impartial to any trade activity. In case of a relation to any trade activity, employee informs IMO-CONTROL and does not entitled for any inspection and certification activity having a conflict with employee’s trade activity.

The inspection documents might be transmitted to other associations or organizations, certifica-tion bodies for certification purpose with specific request of the operator. In this case the opera-tor gives his consent with his signature in the inspection report.

According to Turkish and EU organic Regulations, operation certificates have to be public. For that reason, IMO-CONTROL lists all operators’ names, certification scopes and documentary ev-idences on its website (www.imoturkiye.com).

1.4 Quality Management IMO-CONTROL Ltd. Şti. has built a quality management system based on EN/ISO 17065 standard and assures ist application. In that scope, it has to ensure that all personnel involved in inspections and/or certifications have received appropriate training in the applicable regulations and standards and have access to relevant procedures and quality management documents. It has taken necessa-ry measures to prevent conflict of insterests. All personnel involved in inspections and/or certificati-ons have to declare their conflicts to avoid any impartiality.


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1.5 Costs and Services Costs of inspections are paid by the mandatory (can be different from operator to be certified, such as farmer in a certified group or subcontractor of the applicant). IMO-CONTROL Ltd. Şti. takes care to keep cost as low as possible. Combinations of inspections with other inspection duties are possi-ble. Invoices are issued, based on budgets which have been prepared according to the current fee table and approved with signature by the mandator. IMO-CONTROL Ltd. Şti. reserves the right to keep back the certification decision or the operation certificate until total inspection and certification costs are paid.

2. Application for certification

2.1 Information on the procedure Within working hours, IMO-CONTROL Ltd. Şti. receives questions by e-mail and telephone about Regulation (EG) No. 834/2007 and implementation rules, and the Turkish Organic Regulation „Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik“. Besides verbal information, inter-ested operator can access Turkish and/or English documents with the following details on IMO web-site: EU regulation No. 834/2007 and implementation rules, IMO Organic Standard, the

Turkish Organic Regulation „Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik“ and other regulations can be downloaded from IMO Web site (http://www.imoturkiye.com/, then click on Regulations)

IMO-CONTROL standard control pro-gram

IMO I 2.1.6

Application form for inspection and cer-tification

IMO II 00.1.1

2.2 Application By submitting “Application form for inspection and certification”, the operator shows his interest for the certification procedures.

2.3 Review of Application By receival of application form, application is reviewed considering following articles:

If operator has met necessary conditions for certification (such as plant registry for pro-cessing units, legal structure for group certifications),

If the information about the operator and the product is sufficient for the preparement of bud-get and plan inspections,

If scope of certification has been defined by operator, If there is anough controller and capacity for inspections, If IMO-CONTROL has authorisation and accreditation for requested scope.

If any of above articles is not met, application is not accepted and operator is informed.

2.4 Design of budget and prepayment If review result of application is positive, based on actual fee table a budget is prepared. Accompa-nied with actual fee table, budget proposal is sent to operator. As soon as the operator confirms the offer with its signature and pays the prepayment (as a rule 80% of the total amount), the inspection program starts.


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2.5 Inspection Contract and Description of Operator After approval of budget by operator, contract for inspection and certification (IMO I 4.2.7, IMO I 4.2.5) and its annexes (IMO I Standard Control Programme, IMO I 4.1.3 IMO-CONTROL Fee table, IMO I 4.5.1 Sanction Policy and Catalogue, IMO I 4.5.3 Complaints Procedure) is sent to operator. Regulations and IMO Organic Standard subject to certification can be downloaded from IMO-CONTROL web site (www.imoturkiye.com). Contract has to be signed latest before inspection is executed. This contract is valid until cancella-tion of one of the contract parties. Operator can only handle its products as organic after a successful inspection and certification pro-cess. Signing contract does not mean operator can trade its products as organic. Besides contract, an informational mail attached with an operator profile is sent to operator to inform on inspection preparement. By that means, any known difference in understanding between the certification body and the client is resolved, including agreement regarding standards or other normative documents, before signing contract. EU regulation No. 834/2007 as well as the Turkish Organic Regulation „Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik“ demand, that an operator with interest for inspection shall draw up and subsequently maintain:

a full description of the unit and/or premises and/or activity and

all the practical measures to be taken at the level of the unit and/or premises and/or activity to ensure compliance with the organic production rules.

Therefor the interested operator submits the completed operator profile with all relevant documents which are necessary to describe all operator activities. This is necessary for optimal preparation of first inspection. Operators already in inspection process according EU regulation No. 834/2007 and implementation rules and the Turkish Organic Regulation „Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik“ must provide following documents to IMO-CONTROL Ltd. Şti. as approved or via for-mer certification body.

Contract cancellation letter to former certification body Approved farmer list showing status of farmers, product and production info, plot info, last in-

spection report and annexes informing on nonconformities and corrective actions Last operation certificate Actual stock amount, if applicable Analyze results of last inspection season, if applicable.

3. Preparation for inspection (Preparation for evaluation) The preparation of inspection includes following steps:

3.1 Inspection planning The inspection date is set upon consultation with the operator. The date of inspection for producers is determined by the type of production (crop farming, animal husbandry), for processers by the type of processing as well when a date is available. The inspection date is communicated at least 2 weeks before it takes place. Whilst, IMO-CONTROL keeps its right for unannounced visits. The op-erator is informed that a carefull preparation is essential to carry out inspection quickly, efficiently and professionally. All necessary documents and business data shall be ready for check. The re-sponsible operator staff shall be present. There shall be enough time available. If available, operator


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profile and summary assessment reports are sent attached to inspection announcement to be re-viewed and updated.

3.2 Assigning inspectors The technical manager of IMO-CONTROL Ltd. Şti. appoints the inspector, considering exclusion cri-teria (i.e. conflict of interest (see IMO I 3.2.08)), experience, specific professional knowledge, ap-proval (see IMO I 3.2.07) and time availability. The inspector shall have access to all necessary op-erator documents. He is committed to maintain absolute confidentiality of information (see IMO I 3.3.03). All inspectors are notified to the competent authority and officially approved for carrying out inspections. The inspector / certifier is not allowed to inspect or certify his former employer for 3 years. After 36 months this rule ends. In individual cases, request of the former employer may be evaluated thus period may be prolonged.

To avoid risk of over-familiarity that can cause impartiality, it is not preferred to assign same inspector for inspection of same operator more than 4 years. But that rule may not be applied for scopes require spesific expertise limits the availability of qualified personnel (such as husbandry inspections).

4. Inspections (Evaluation)

4.1 Definition The inspection is an essential part of the evaluation process: The inspector detects violations by documentary proof. It is important that the decision is transparent. The results of the inspection re-port are given to the operator with necessary measures to correct violations immediately. Violations and measures are written in the Summary Assessment form which is countersigned by the operator to confirm the content. After inspection all inspected documents are compiled at IMO-Control office, put in order, filed and transferred to computer, possibly translated. Then the complete inspection re-port, including Operator Profile, Summary Assessment and necessary attachments are sent to the certifier for certification. The certification according to Turkish organic regulation “Organik Tarımın Esasları ve Uygunlanmasına İlişkin Yönetmelik” and the IMO Organic Standard equivalent to EU organic regulation 834/2007 is carried out in İzmir by IMO-CONTROL Ltd. Şti. approved staff (certi-fier). This process is a four-eyes principle which means that inspection/evaluation and certification are done by two different persons.

4.2 Execution of inspection 4.2.1 Basics

IMO-CONTROL Ltd. Şti. carries out a complete inspection of production/processing units or other operating units at least once a year. Duration of inspection is determined by the type of operator and the scope of activities under inspection. By the signed contract, operator guarantees IMO-CONTROL Ltd. Şti. or its inspectors to access to all parts of the unit and all premises, as well as to the accounts and relevant supporting documents and to provide the control body with any information reasonably and necessary for the purposes of the control. The inspected operator has the possibility to assign IMO-CONTROL Ltd. Şti.for assessment of fur-ther standards or inspections of private or public quality management programs. If possible these inspections are coordinated at the same time with inspections according EU Regulation No. 834/2007 and implementation rules and the Turkish Organic Regulation „Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik“. With special request of the inspected operator by signing the


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„data release declaration“ on inspection report, inspection documents also can be transmitted to 3rd parties and certification parties for private certification standards.

4.2.2 Process of inspection The inspection is divided in several parts. The inspector decides on the order of the following steps: Opening meeting, summarizing the aim of visit and declaration of confidentiality and impartiality

principles of IMO-CONTROL and its inspector

Initial discussions with the staff in charge

Screening and updating all basic operation documents such as product list, documents of ani-mal identification and animal inventory, premise plans, farm and field maps, etc. and possible completion thereof

Verification of agreed measures described in the operator profile to ensure compliance with the applicable standard(s). In this context the operator provides IMO-CONTROL Ltd. Şti. also with results of internal audits and self monitoring programs.

Touring (buildings, premises, fields, etc)

Interview with neighbours and regional competent authorities

Risk based sampling and analysis can be done to proof any suspicion on use of unallowed substances or to monitor conforming production methods. In case of suspicion sampling is compulsory. IMO CONTROL Ltd. Şti. works exclusively with laboratories accreditated according to EN ISO/IEC 17025 to analyze samples. The inspected operator agrees on sampling with the signature under the inspection contract. In individual cases this can also concern different activi-ty fields (i.e. experts).

Verification of operator description (operator profile) and screening specific documents such as supplier list, recipes, farm diaries on input application, livestock buildings cleaning and disinfec-tion records, packing records, storage records, general farm input, etc

Inspection of the book keeping. Checking of the receipts, purchase records and sales documen-tation in order to follow up the product flow (=compare purchase and sales quantities of one op-erator in the supply chain).

For routine testing (i.e. in case of big supply amounts) or in case of suspicion (i.e. inconsistent product flow, unclear labeling of supply) the inspector may exchange and cross check infor-mation on the result of control with other competent authorities, control authorities and control bodies according to EU regulation 834/2007 Article 31 and EU regulation 889/2008 Article 92 and ile Turkish Organic Regulation “Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönet-melik” Article 41 (1) (ğ).

Compiling the inspection report including the Summary Assessment which documents devia-tions and non-compliances according to the IMO Organic Standard equivalent to EU regulation No. 834/2007 and Turkish Organic Regulation „Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik“. The operator is obliged to countersign this summary assessment report and take all necessary measures to ensure compliance with the organic production rules. Operator has the right to put an annotation on findings. A copy of the Summay Assessment either re-mains at or is sent immediately after inspection to the inspected operation.

Final discussions with the project manager about general results of the inspection, necessary improvements and measures etc.

4.2.3 Inspection report The inspection report includes a series of documents depending on the type of activity (see the file „II TR Document overview“).


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4.2.4 Summary Assessment Report (Evaluation Report) Non-conformities found during inspection are documented by the inspector with the template “Sum-mary Assessment”. In the frame of the evaluation process, the inspector proposes respective ac-tions and measures to be performed by the operator, which should guarantee that the non confor-mity is immediately resolved and all measures effectively applied.


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4.2.5 100% inspection of small holder groups (IMO II 25.xx):

25.x.x Groups with 100% Inspection

4.2.7 Inspection Contract (only in case of new operators/operator names)

NOP Inspection Contract 4.2.2 and 4.2.22 (just tick NOP)

JAS Inspection Contract 4.2.2 and 4.2.22 (just tick JAS)

25.1A Group Operator Profile

25.3A Authorisation

25.1.7 JAS Farm application form and production plan

25.1B Operator Profile Project Centre for following centres:

25.3B Inspection Report Project Centre

4.3.4 Inspector Guide Paralel Production (only in case of paralel production)

4.3.5 Retrospective Aprroval Application

25.3.1B Additional Inspection Report Project Centre NOP

25.3.7 Additional Inspection Report JAS Project Centre

25.4.1C Farm Inspection Report

25.5 Summary Assessment

Group operator

h/c h/c h/c e e

Project centre

e e e e e

e

e/c

Farmer h/c

4.2.6 Individual producers (IMO II 04.xx):

4.x.x Farm Operations




4.1 Operator Profile Farm

4.4.1 Field History Farm (only in case of new farm or new plot)


4.3 Inspection Report Farm

4.3.1 Additional Farm Inspection Report NOP



4.3.7 Additional Inspection Report JAS Farming Operations


Main Operator h/c h/c h/c Farm e e e e e e e e e/c


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4.2.7 Processors and Exporters (IMO II 10.xx)-including yeast and feed production:

10.x.x Processing and or Export Operations


4.2.5 Inspection Contract (subcontractors/storages)



10.1 Operator Profile Processor/Exporter

10.1.1 Recipe Sheet

10.1.7 JAS Processor application form and production plan

10.3 Inspection Report Processing/Export Operations

10.3.1 Additional Inspection Report Processing/Export Operations NOP

10.3.7 Additional Inspection Report JAS Processing Operations

10.3.10 Additional Inspection Report Processing Feed

10.4.1 Checklist Warehouse (for each warehouse at separate and professional warehouses)


Main Operator h/c h/c h/c h/c Processing Unit h/c e e e e e e e e/c Warehouse h/c e/c

4.2.8 Wild Collection (IMO II 15.xx):

15.x.x Wild collection




15.1 Operator Profile Wild Colection


15.1.1 Specification Collection Area (s)

15.1.2 Specification Collection Goods

15.1.3 Summary of Collection Activities

15.3 Inspection Report Wild Collection

15.3.7 Additional Inspection Report JAS Wild Colection

15.4.1 Checklist Interview Collector

15.4.2 Checklist Purchase Centre (for each purchase centre one)


Main Operator h/c h/c h/c e e Purchase centre e e/c Per Collection area e e e e/c Per Product e Per insp. collector h


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4.2.9 Beekeeping (IMO II 17.xx): 17.x.x Apiary/Honey Operations




17.1 Operator Profile Farm

17.1.1 Flowering Calendar

17.1.2 Migration Records

17.3 Inspection Report Apiaries

17.4.1 C Inspection report Apiarist

17.4.1 Inspector Guide: Honey House


Main operator h/c h/c h/c Project centre

e e

e/c

Per location

e e

Per honey house

e/c

Apiarist h/c

4.2.10 Aquaculture (IMO II 20.xx): 20.x.x Aquaculture Operations

4.2.7 (only in case of new operators/operator names)

20.1 Operator Profile Aquaculture

20.3 Inspection Report Aquaculture

20.3.5 Inspector Guide Retrospective Approval Aquaculture

20.5.9 Summary Assessment

Main Operator h/c Unit 1 e e e e/c


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4.2.1 Animal Husbandry 16.x.x Farm Operations


16.1 Operator Profile Farm with certified Livestock

4.4.1 Field History Farm (only in case of new farm or new plot)

16.3 Inspection Report Animal Husbandry in third countries

16.3.2 Additional Report Ruminants

16.3.4 Additional Report Poultry

16.3.5 Purchased and planted feeding stuff




Main Operator h/c Farm e e e h/c h/c e e e e/c

4.2.2 Group Certification with ICS

h: hardcopy e: electronic version c:copy to operator Inspection reports for private labels (such as Bio Suisse, Demeter, Naturland, etc) are designed by label organization.

14.x.x ICS Group Projects




14.1 Operator Profile ICS

14.3 Inspection Report ICS



14.3.1 Additional Inspection Report for NOP ICS

14.3.7 Additional Inspection Report JAS ICS

14.4.1 Farm Inspection Report

14.4.2 Checklist Purchase Center

14.4.3 VisitingReport Form


Grup operatö-rü

h/c h/c h/c

Proje bölgesi

e e e e e e e/c

Üretici h/c Satınalım Merkezi

e/c


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4.3 Review Once the physical inspection report has been transferred to a computerized version, a consistency check will be done by expert staff of IMO-CONTROL Ltd. Şti. (this person might not be involved as an inspector for the same operator). A data reconciliation-check is done and any contradictions, vagueness and open questions are clarified with the inspector. The measures and actions proposed by the inspector in the Summary Assessment are checked for equal treatment and non-discrimination of the operator and sanctions are applied according IMO sanction policy and cata-logue for Turkey (IMO I 4.5.1). Afterwards the report is sent to certifier for certification decision. Review and certification can be done by same person.

5. Desicion on certification (Certification)

5.1 Certification procedure The certification procedure of IMO-CONTROL Ltd. Şti. includes generally the assessment of the in-spection report and summary assesment report, written by inspector and signed by mandator/operator, including relevant documental evidences. This assesment is done by approved certification staff. Period for certification process (time interval between inspection visit-evaluation- and certification) has been defined as maximum 4 months and performance is monitored. The fol-lowing steps are followed by certifier:

Formal check of completeness of documents and compliation to regulations: internal checklist certification (IMO I 2.2.4), etc.

Certification is possible only following are fulfilled:

a) The evaluation results are totally satisfying.

b) A valid contract exists between operator and IMO-CONTROL Ltd. Şti.

c) The prepayment of inspection has been received.

The certificate (certification of operation) ensures a positive inspection procedure. Validity of opera-tion certificates is given as 31st December of following calendar year to inspection year. In addition to the certificate of operation, a lot certificate has to be issued for each product sale. A work instruc-tion (TR11) is available for lot certification and open for operators on request.

The operator receives the final invoice about inspection costs according to the current fee table or the budget agreed on. Lot certificates are invoiced for last year annually in January every year.

5.2 Non-compliances Non-compliances from the inspection report are reported to the operator by the summary assesment report as written. Deadline for fulfillment of nonconfirmities is 1 month according to Turkish Organic Regulation. For conditions not fulfilled within a month, corrections are imposed according to their severeness. They are determined in the sanction policy and catalogues of IMO-CONTROL (IMO I 4.5.1). Finalised inspection and summary assesment reports after review are sent to operator accompanied by written notification (IMO I 4.6.3). These final reports may include amendments done during re-view and certification. These amendments are definable by operator (in red letters on operator pro-file and conditions on summary assessment defined by an asterix). Operator is asked to sign and send documents back to IMO-CONTROL office. As such, the operator acknowledges the deviations


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and conditions with his signature on a specific report. Operator has the right to appeal the decision officially within 14 calender days after receival of decision. Follow-up of deadlines for sanctions/limitations/conditions is checked by IMO-CONTROL by dossier of operator.

5.3 Denial of certification When correction of a major non-compliance is not possible or has not been fulfilled within deadline, a notification or denial of certification is sent to the operator. An operator with denial of certification shall not label its products with reference to organic production according to EU Regulation No. 834/2007 and the Turkish Organic Regulation „Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik“. The competent control authority in Turkey is informed by annual report. In case of se-vere conditions of single farmers of a certified group, the respective farmer is decertified according to Sanction catalogue (IMO I 4.5.1) and certification status is mentioned on approved farmers list accordingly. Also decision of certification denial is noted on summary assessment. The respective farmer may not sell his products with reference to organic production.

5.4 Responsibilities of operator Operator is responsible of; Apply necessary changes on regulations and standards and informed by IMO-CONTROL Ltd.

Şti. in given time; Ensure the certified product continues to fulfil the product requirements in certification scope; Uses certification only to indicate that products are certified as being in conformity with specified

regulations; Makes claims regarding certification only in respect of the scope for which certification has been

granted; Does not use its product certification in such a manner as to bring IMO-CONTROL Ltd. Şti. into

disrepute and does not make any statement regarding its product certification which IMO-CONTROL Ltd. Şti. may consider misleading or unauthorized;

Upon suspension, withdrawal or cancellation of certification, discontinues its use of all advertis-ing matter that contains any reference thereto and returns any certification documents as re-quired by IMO-CONTROL Ltd. Şti.;

Endeavours to ensure that no certificate or report nor any part thereof is used in a misleading manner;

In making reference to its product certification in communication media such as documents, bro-chures or other advertising, complies with the requirements of IMO-CONTROL Ltd. Şti.

Apply rules of IMO logo use as described on that document (article 7).

6. Surveillance (Continuation of certification)

6.1 Communication The operator must communicate in time any substantial changes of activities, such as changes on production and processing process, inputs to be used on farm, changes at organization and quality management, new processing units/farms, new activity/product/supplier/consumer label and change of address, cancellation of any authorises given by authorities which are precondition for certification (such as plant approval or plant registry) or implemented measures to ensure compliance with the standard. IMO-CONTROL Ltd. Şti. sends the operator profile attached to annual inspection announcement and requests explicitly to update it. This update profile must be sent back to control body latest be-fore inspection.

6.2 Follow-up inspections IMO-CONTROL Ltd. Şti. carries out at least once a year a full inspection of each operational unit as described in part 3 and 4. In case of a non-confirmity which needs additional inspection according to


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sanction catalogue, IMO-CONTROL Ltd. Şti. may perform additional inspections and spot-check inspections which are invoiced to operator according to actual fee table.

6.3 Changes affecting certification Changes on regulations and standards affecting certifications and operators are informed by email or post. Operator has to apply necessary changes in its system. To verify implementation of chang-es, IMO can conduct additional inspections and spot checks or request additional documents/proofs for report updates which are invoiced to operator according to actual fee table.

6.4 Decision about renewal of certification Based on the results of the annual on-site inspection, additional inspection, spot-check inspections and all updated information, IMO-CONTROL Ltd. Şti. decides if the certification may be updated (see procedure of chapter 5). In case of non-compliances, procedures described at chapter 5.2. and 5.3 are applied.

6.5 Decision about scope amendment of certification If mandator requests for scope amendment, decision about an on-site inspection is given by IMO-CONTROL Ltd. Şti. If extension of certification according to a different regulation or activity scope is requested, proce-dures from chapter 2 to 5 are applied (whole inspection/evaluation and certification process). If op-eration certificate is subject to change due to new products produced/processed at the same system (farm/ processing line/ quality management) certified with the last annual inspection, certification body decides if whole inspection and certification procedure shall be applied or if certification of new product is applicable after handing additional information by mandator on revised operator profile with necessary attachments (i.e; supplier operation certificates, origin document of seeds, recipes, etc.) and checking of such documents.

6.6 Withdrawal of certification (termination, reduction, suspension or withdrawal) Certificates or the right to claim products as organic can be withdrawn immediatly or within a dead-line in the following cases:

Operator cancels the contract.

Certification body cancels the contract.

If there are doubts on behalf of the operator or the certification body that any used product does not meet the organic production rules, the product cannot be marketed as organic unless all doubts have been eliminated. (EU regulation 889/2008 Article 91, the Turkish Organic Regula-tion“Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik” Article 42)

In case of severe non-compliance with the organic production rules (EU regulation 834/2007 Ar-ticle 30, the Turkish Organic Regulation “Organik Tarımın Esasları ve Uygulanmasına İlişkin Yö-netmelik”Article 42).

Denial of inspection

Denial of information

Attempted fraud or willingly false statement

No payment to IMO-CONTROL in due time

Non-compliance of corrections and conditions

Withdrawal of certificate can result in one or a few of following actions: continuation of certification under conditions (e.g. increased surveillance); reduction in the scope of certification to remove nonconforming product variants;


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suspension of the certification pending remedial action by the client; withdrawal of the certification.

Recall of products.

In all cases IMO-CONTROL informs operator by a written notification with decision and deadlines.

If certificate is suspended, lot certificates are not issued.

If certificate is reduced, actual certificate is published on website immediately.

If certificate is terminated or withdrawn and if last operation certificate is issued has not yet terminat-ed, to avoid misuse use and public information, reason for action and necessary information are published on website.

Also there is an information note on certificates that last version and validity has to be confirmed on website.

6.7 Unannounced visits and spot-check inspections 6.7.1 Annual spot-check frequency

To ensure a high product safety, IMO-CONTROL Ltd. Şti. performs risk-oriented additional spot-checks (unannounced and announced), besides necessary annual inspections. Such inspections do not focus on all areas of inspection but only risky areas (such as purchase, product flow calcula-tions, etc) Clasification of risk classes are determined in the following table. They also depend on the Risk As-sessment in the IMO Operator Profile, on results of former inspections, product quantity and con-tamination/commingling risk. The amount of announced and unannounced spot-checks depends on the risk clasification. Per-centages of additional spot-checks are as following on basis of number of operators under control: 10% of each category low risk (I), potential risk (II), high risk (III). Number of unannounced inspec-tions are performed as following on basis of total number of annual and spot-check inspections: 10% of each category low risk (I), potential risk (II), high risk (III). Spot-checks are documented in relevant inpection report or IMO II 21.4 Spot-Check Report and evaluated according to the standard procedure by competent staff of IMO-CONTROL Ltd. Şti.. In cases of severe violations the operator receices a separate notification. In cases of severe violations during sport-check, the control body can ask and charge additional in-spections. Costs of spot-checks are charged to the operator based on the actual fee table of IMO-CONTROL Ltd. Şti..

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6.7.2 Risk analyze Criterias of risk clasification Criteria and inspection area

İ low risk: all of the following criterias must be fulfilled to determine the risk class as I

II potential risk: at least one of the following criterias is relevant to determine the risk class as II

III high risk: at least one of the following criterias is relevant to determine the risk class as III

1. Trade and market of product Trade Organic turnover is below 250‘000 TL (appr.

100‘000 euro) Organic turnover is below 5‘000‘000 TL (appr. 2‘000‘000 euro) Organic turnover is over 5‘000‘000 TL (appr. 2‘000‘000 euro)

Competition There are a few companies in the sector and/or competition is low.

Market of company is over 10% and/or competion is average.

Company is leader at the sector and/or competition is high.

2. Complexity of company, number of suppliers and subcontractors Structure and complexity

Only one premise Up to 3 premises More than 3 premises

Number of suppliers

Up to 5 suppliers Up to 10 suppliers More than 10 suppliers

Subcontractor None Up to 3 subcontractors More than 3 subcontractors

Trader Delivery/trade as packed and labelled Delivery/trade as packed but not labelled Delivery/trade as bulk, unpacked

3. Changes in company ownership and senior employee Changes in company ownership and senior employee within last 2 years

No changes No changes since last annual inspection Change since last annual inspection

4. Appropriate Internal Quality Assurance System Quality Assurance System

There is a risk assessment for operator and determined risk is low or medium. Only organik products are handled or ISO9000 or HACCP is applied and certified.

There is a risk assessment for operator and determined risk is high. ISO9000 or HACCP is applied and but not certified for organic products.

There is no risk assessment for the operator. ISO9000 or HACCP is not applied.

5. Tarımsal Üretim Birimi Tarımsal Üretim

Considering conventional production methods, risk of unallowed input use is low for the certified crop. No conventional production as cash crops. No parallel production Risk category is set as I on operator profile.

Considering conventional production methods, risk of unallowed input use is medium for the certified crop. Conventional production as cash crops No parallel production Risk category is set as II on operator profile.

Considering conventional production methods, risk of unallowed input use is high for the certified crop. There is a parallel production Risk category is set as III on operator profile.


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Criterias of risk clasification Criteria and inspection area

İ low risk: all of the following criterias must be fulfilled to determine the risk class as I

II potential risk: at least one of the following criterias is relevant to determine the risk class as II

III high risk: at least one of the following criterias is relevant to determine the risk class as III

6. Processing Processing simple processing like drying, cleaning, grinding

(only single agricultural ingredient, without addi-tives and processing aids)

Change of consistency during processing (oil mill, toast-ing, cooking, baking) but no processing aids/additives except water and salt

Complex processing with processing aids/ additives except salt, water

Separation Only processing of organic products OR pro-cessing of organic and conventional products in own or a contracted operator of very little amount in defined time

Processing of organic and conventional in big amounts and/or in undefined times

Processing of organic and conventional in big amounts and/or in undefined time Product supply from many different suppliers Critical control points during processing: risk of contamination or commingling because of processing technique

7. Results of last inspections History Certified by IMO-CONTORL more than 1 year First Certification ---

Conditions No conditions or only conditions of the sancion category I-II (see TR I 4.5.1 Sanction policy)

conditions of the sanction category İVa (warning) (see TR I 4.5.1 Sanction policy)

Conditions of sanction category III, IVb (except from documents to be handed after inspection, such as GMO declaration, labeli, etc) and higher (see TR I 4.5.1 Sanction policy) Obvious ignorance of conditions (i.e. notification not read, unsufficient knowledge, etc)

Cooperation with IMO

constructive collaboration

minor difficulties in collaboration major difficulties in collaboration

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6.8 Sampling Sampling is an important tool to check the quality of organic products and can effect the decision of certification. IMO-CONTROL Ltd. Şti. compiles for each project an individual annual sampling pro-gramme. Samples are taken according to these programmes and exclusively analyzed in accreditated laboratories. Details are determined in a separate policy paper (TR I 4.6.1). The number of samples to be taken every year correspond to at least 5% of the number of operators under control.

6.9 Cases of suspicion and complaints Where an operator considers or suspects that a product which he has produced, prepared, imported or received from another operator, is not in compliance with EU regulation No. 834/2007 and Turk-ish Organic Regulation „Organik Tarımın Esasları ve Uygulanmasına İlişkin Yönetmelik“, he shall ini-tiate procedures either to withdraw from this product any reference to the organic production method or to separate and identify the product. He may only put it into processing or packaging or on the market after elimination of doubt, unless it is placed on the market without indication referring to the organic production method. In case of such doubt, the operator shall immediately inform the control body or authority. The operator obligates himself to notify IMO-CONTROL Ltd. Şti. if he knows or suspects any appli-cation including a drift of a prohibited substance to any of fields, livestock or part of processing unit as well as any contamination to or commingling of organic products and inconversion/conventional products. In cases of suspicion the control body works according to a crisis plan to identify severe violations in time and clear circumstances efficiently. If there is a complaint on certified operator from 3rd parties (such as other inspection and certification bodies, buyers, etc) or authorities is taken, IMO-CONTROL checks first if complaint is in about certification activity under its responsibility. If it is, conducts necessary investigations and takes necessary measures. If needed, parties and authori-ties are informed on investigation results and measures taking confidentiality into consideration. Such investigations are invoiced to operator on basis of actual fee table. The mandator maintains the records about all the reported objections/complaints with respect to the conformity of all products with the specifications of the applicable regulations as well as necessary corrective measures applied and grants IMO-CONTROL access to all these records.

7. Use of licenses, certificates and marks of conformity

7.1 IMO-Logo As described in the general trademark policy (IMO I 2.5.1) the IMO trademark may be used for label-ling by certified operators as long as a valid contract with IMO exists and IMO has certified their products. The use of the trademark is bound to the condition that all packaging designs must be sent to IMO-CONTROL Ltd. Şti. for review and approval before printing. The use of the trademark is free of charge.


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Certification does not give right to operator and is not legal to use logo of IMO-CONTROL accredita-tion body.

7.2 Private Labels The possibly use of private labels must be agreed upon the trademark holder and the operator in a separate contract.

8. Appeals, Complaints and Disputes

8.1 Complaints Complaints about applied procedures and inspection and certifying staff of IMO-CONTROL Ltd. Şti. are evaluated on a defined complaint procedure (IMO I 4.5.3).

8.2 Appeals Appeals against certification decisions, conditions and sanctions, contract cancellations or rejection of applications are dealt with as follow:

8.2.1 Standard procedure

The operator is informed about his right to appeal by the following indication in the certification notification: “This decision may be appealed to IMO-CONTROL Ltd. Şti officially within 14 calen-der days after receival of the certification letter.“

IMO-CONTROL Ltd. Şti. deals with the written appeal and checks individually the possible scope of action. The result is notified in written to the operator.

If no agreement is found (case of dispute), the appeal is treated according to the defined com-plaint procedure (IMO I 4.5.3). In case of dispute, Turkish authority is informed within 21 days after written appeal is taken as well. Appeals and compliants are handle by competent authority and final decision is informed to parties.

Result and close of appeal is informed officially to applicant.

8.2.2 Cancellation of contracts According to the contract, there is no right to appeal cancellations if cancellation was not made in time (latest 30 november). Immediate cancellations of contracts are always subject to approve by the managing board of IMO according to the standard procedure of complaints. Operators who cancel their contracts receive a cancellation letter. By that letter operator is informed on cancellation reason, that its certificate is terminated and right to use any indication referring IMO-CONTROL certification and IMO Logo on advertisement material, web site, labels and invoices is no longer valid. Also if its certificate does still have validity with date, operator is listed on web site un-der cancelled certificates. All services not yet invoiced at date of cancellation (inspections, reporting, office works, lot certificates, etc) are invoiced according to signed budget or actual fee table.

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