Conference of the Anti-Fraud-Initiative

Handles, keys, and levers for investigation of residue cases in organic production – Good implementation practices for Articles 28  and 29 of Reg. 2018/848 

The conference took place on 25 and 26 January 2024 in Brussels and was organized by BLQ on behalf of the "Anti-Fraud-Initiative" (AFI).

Presentation of Good implementation practices for Articles 28 and 29 of Regulation (EU) 2018/848.

The Context

The question of the presence of “non-authorised products or substances” (currently mostly pesticide detections) in organic products has been one of the main sticking points in the organic reform. The compromise found, reflected in the basic act 2018/848  in its articles 28 and 29, is based on three main points:

1. An organic product does not necessarily have to be residue free.
2. However, a product containing non-authorised substances can only be marketed as organic if it is established that the operator has not used these pesticides, commingled or even replaced organic with conventional products, if he has taken the necessary measures to avoid this contamination and to respond to previous requests from the control bodies.
3. Verification that these conditions are met can be done by the operator himself, by checking if the suspicion of non-compliance with the regulation can be eliminated, and, if not, by the CB by investigating the source and the cause of the contamination.

Organic production must comply with many other objectives and principles than the issue of non-authorized substances. However, residue analyses of pesticides have taken a central place in the control and certification of organic products. A laboratory result is considered to be of tangible and quantifiable nature; pesticide residues are still an important marking for the consumer of organic products. After a year of implementation of the new regulation, the issue has generated numerous reactions and discussions.

Get in touch with us and contribute your ideas
Contact points for sending proposals an solutions to chapter coordinators

Presentations

Chapter 1 Contaminants found in food (Reviewed)
Rodolphe Vidal (FR), Rosi Fritz (DE)

• Statistics on contamination
• Substances most frequently found, on what types of organic products
• Comparison with conventional products 

Chapter 2 Laboratory analysis
Felix Lippert (DE)

• Detection from lab analysis: overview of current methods
• Limitations of lab analysis, sampling, reliability, limit of detection and quantification
• Specific issues (Difference in contamination on the cultures and the final product, remanence, concentration in dry products, etc.)

Chapter 3 Major sources and causes
Bernhard Speiser (CH)

• The key issue: identifying source and cause of a contamination  

Chapter 4 Methods and techniques for official investigations (Reviewed)

Tom Nizet (BE), Lea Bauer (HU)

• Documentary analysis
• Mass-balance and traceability
• Additional inspection visits (announced/unannounced)
• Information exchange

Chapter 5 Systematic approach for investigations
Jochen Neuendorff (DE), Nicolas Verlet (FR)

• Preparatory work: risk analysis, use of previous data (reports, analyses, etc.)
• Setting up an investigation methodology

Chapter 6.1 Assessment conducted by operators (Reviewed)
Alexander Beck (DE), Bernard Lignon (FR)

Chapter 6.2 Investigation conducted by Certification Bodies
Sergiy Galashevskyy (UA), Samanta Rosi Belliere (IT)

Chapter 6.3 Investigations conducted by competent authorities in member states
Nicolas Verlet (FR)

Chapter 6.4 Information exchange,
Maresca (IT), Roberto Setti (IT)

Chapter 7 Decision making
Jochen Neuendorff (DE), Nicolas Verlet (FR), Bernhard Speiser (CH)