Guidance for companies in case of suspicion of non-compliance with EU regulation

According to Articles 27 and 28 (2) of the new EU Regulation 2018/848, which will become legally effective in January 2022, companies must check whether a suspicion is "substantiated" or can be "eliminated" in case of suspicion that the product does not meet the requirements of the regulation. The Implementing Regulation (EU) 2021/279 further specifies the requirements for companies, control bodies and control authorities. However, the regulation does not cover in detail the systematic procedural steps to check whether the suspicion can be "substantiated" or "eliminated".

How should a reasonable initial evaluation of analytical findings be carried out? How do I check whether it is relevant information that substantiates a suspicion of a violation against the organic regulation? What minimum information should usefully be provided with analysis results? What are the tasks of the actors involved and what information should be exchanged?

The new guideline meets these and further questions. The guidance was developed as part of the BÖLN project "PSM-Wirkstofffunde" (Pesticide and active ingredient findings) by the Office of Food Science and Quality (BLQ) and the Research Institute of Organic Agriculture (FiBL Germany). It is available for free download on the orgprints.org website.

Further information

Contact

Marlene Milan

Links

• orgprints.org: "How do I proceed in case of a possible non-compliance with the Organic Regulation (Regulation (EU) 2018/848) according to Article 27 or Article 28 (2)?" - Quality Management Guide
• fibl.org: Project description "Problem analysis and identification of required action in the field of pesticide residues along the organic value chain"
• fibl.org: FiBL Residues Working Group