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Ares(2020)2060672 - 15/04/2020

EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY

Health and food audits and analysis

DG(SANTE) 2019-6727

FINAL REPORT OF AN AUDIT

CARRIED OUT IN
TURKEY
FROM 19 TO 28 NOVEMBER 2019
IN ORDER TO
EVALUATE CONTROLS OF PESTICIDES IN FOOD OF PLANT ORIGIN INTENDED
FOR EXPORT TO THE EUROPEAN UNION

In response to information provided by the competent authority, any factual error noted in
the draft report has been corrected; any clarification appears in the form of a footnote.
 Executive Summary

This report describes the outcome of an audit in Turkey carried out from 19 to 28 November 2019,
as part of the published Directorate-General for Health and Food Safety audit programme. The
objectives of the audit were to assess controls on pesticide residues in fresh fruit and vegetables,
in particular sweet peppers, citrus fruits and pomegranates intended for export to the European
Union (EU).

Overall, the authorities have adopted a number of measures to help meet the EU requirements
with regard to pesticide residues in food, and to improve the effectiveness of pesticide controls.
These include initiatives to implement Integrated Pest Management principles and/or bio-control
methods, training of growers and advisors, extending the pre- and post-harvest sampling, export
controls and systematic follow-up of Rapid Alert System for Food and Feed (RASFF) notifications.
However, these have had very limited impact so far.

The effectiveness of the system is compromised in particular by the inadequate training and
authorisation/certification of advisors and growers applying plant protection products (PPP), by
the limited controls on PPP use at farm level, and the insufficient controls at pack houses and
exporters, mainly due to inadequate traceability of produce throughout the food chain, the lack of
legal requirements to record post-harvest PPP treatments, and not covering aspects related to
potential chemical treatments of empty storage facilities and means of transport.

Moreover, most of the efforts and resources for official controls come quite early in the food
chain, putting the emphasis in the pre-harvest stage rather than in the post-harvest period, which
does not allow for better assurance that the final products would meet the EU requirements.

Investigations in response to RASFF notifications not being able to identify the root causes, and
the lack of or the very limited own controls by Food Business Operators raise further concerns
with regard to ensuring compliance with EU standards.

The report makes recommendations to the competent authorities to address the shortcomings
identified.

I
Table of Contents

1 Introduction ....................................................................................................................................1
2 Objectives and scope......................................................................................................................1
3 Legal Basis and Standards .............................................................................................................2
3.1 Legal Basis ..............................................................................................................................2
3.2 Standards .................................................................................................................................2
4 Background ....................................................................................................................................2
5 Findings and Conclusions ..............................................................................................................4
5.1 Relevant National Legislation .................................................................................................4
5.2 Competent Authorities.............................................................................................................5
5.3 Official Controls of the Marketing and Use of Plant Protection Products ..............................5
5.3.1 Authorisation of Plant Protection Products.....................................................................5
5.3.2 Control of the marketing of Plant Protection Products ...................................................6
5.3.3 Control of users of Plant Protection Products.................................................................6
5.4 Official Controls of Pesticides Residues in Food of Plant Origin.........................................11
5.4.1 Post-harvest control for pesticide residues....................................................................11
5.4.2 Control at Exporters ......................................................................................................12
5.4.3 Laboratories for Pesticide Residue Analysis .................................................................14
5.5 Response to RASFF Notifications.........................................................................................17
5.6 Private Controls on Fruits and Vegetables Exported to the EU ............................................17
5.7 Follow up...............................................................................................................................18
6 Overall Conclusions .....................................................................................................................20
7 Closing Meeting ...........................................................................................................................20
8 Recommendations ........................................................................................................................20

II
ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT

Abbreviation Explanation
CA(s) Competent Authority(ies)
CAC/GL Codex Alimentarius Commission/Guideline
CODEX Codex Alimentarius Commission of the Food and Agriculture Organization
of the United Nations and World Health Organization
DG Directorate General
EU European Union
FAPAS Food Analysis Performance Assessment Scheme
FBO(s) Food Business Operator(s)
GDFC General Directorate Food and Control
GC-MS/MS Gas Chromatograph coupled to tandem mass spectrometer
ha hectare(s)
HPLS high-performance liquid chromatography
HRAMS high-resolution accurate mass spectrometer
IC Ion Chromatograph
IPM Integrated Pest Management
ISO International Organisation for Standardisation
LC-MS/MS Liquid Chromatograph coupled to tandem mass spectrometer
LOQ limit of quantification
MAF Ministry of Agriculture and Forestry
MRL(s) Maximum Residue Level(s)
MRM(s) Multi-Residue Method(s)
MS(s) Member State(s)
NRL National Reference Laboratory
PFCD Provincial Food and Control Directorate
PPP(s) Plant Protection Product(s)
PT(s) Proficiency Test(s)
RASFF Rapid Alert System for Food and Feed
SRM(s) Single-Residue Method(s)

III
1 INTRODUCTION

This audit took place in Turkey from 19 to 28 November 2019 as part of the Directorate-
General for Health and Food Safety’s planned audit programme.

The European Commission team consisted of two auditors from the DG Health and Food
Safety and one expert from a European Union (EU) Member State (MS). It was accompanied
throughout the audit by representatives of the central competent authority (CA). An opening
meeting was held on 19 November 2019 in Ankara with the relevant CAs, during which the
objectives of and itinerary for the audit were confirmed and additional information necessary
for the conduct of the audit was requested.

2 OBJECTIVES AND SCOPE

The objectives of the audit were to verify whether there are systems in place for the control of
pesticide residues in food of plant origin intended for export to the EU, and assess whether
these systems offer adequate assurance that the produce concerned is within the specified
residue limits as laid down in EU legislation.

In terms of scope, the audit reviewed the controls in place on production and export of citrus
fruit, sweet peppers and pomegranates, including a review of national legislation, CA
organisation, their controls and enforcement capability, facilities (laboratory capability) and
measures in place for the determination of pesticide residues in the above listed commodities.
As the residue controls are directly related to the national rules governing the authorisation,
placing on the market and use of Plant Protection Products (PPPs), the control systems in this
area were also part of the audit.

In pursuit of these objectives, the following sites were visited:

Competent Authorities Comments

Competent Authorities
Laboratories
Official laboratories
Private laboratories
Central: General Directorate of Food and
Control (GDFC) of the Ministry of
Agriculture and Forestry (MAF), Ministry of
Foreign Affairs and Ministry of Trade
Regional: Mersin and Antalya Provincial
Food and Control Directorates (PFCDs)
1 one laboratory in Antalya
1 one laboratory in Mersin

1
Producers
Growers
Exporters/Pack-Houses
Exporters of fruit and vegetables
Exporters' associations
3 In Mersin: one grower of citrus fruit for
export to the EU;
In Antalya, one grower of sweet peppers and
one grower of pomegranates for export to the
EU.
3 three exporters of fresh fruit and vegetables
to the EU
two Exporters associations, one in each of
2
both regions visited, Mersin and Antalya

3 LEGAL BASIS AND STANDARDS

3.1 LEGAL BASIS

The audit was carried out under the general provisions of EU legislation, in particular, Article
46 of Regulation (EC) No 882/2004 of the European Parliament and of the Council, which
stipulates that EU controls in non-EU countries, may verify compliance or equivalence of
non-EU countries legislation and systems with EU feed and food law and EU animal health
legislation. These controls shall have particular regard to the assurances, which the non-EU
country can give regarding compliance with, or equivalence to, EU requirements.

EU legal acts quoted in this report refer, where applicable, to the last amended version. Full
references to the EU acts quoted in this report are given in Annex 1.

3.2 STANDARDS

Guidelines and Codes of Practice of the Codex Alimentarius Commission of the Food and
Agriculture Organisation of the United Nations and World Health Organisation (CODEX)
were also taken into account in this audit.

A full list of applicable standards referred to in this report is provided in Annex 2. Reference
to specific provisions of these texts is provided at the beginning of each section.

4 BACKGROUND

The DG Health and Food Safety has carried out audits in a large number of exporting
countries to assess official controls for pesticide residues in food of plant origin originating
from these countries. The reports on these audits are available on the internet site at
http://ec.europa.eu/food/audits-analysis/audit_reports/index.cfm.

This was the eighth audit to Turkey with the same scope, and it also followed up
recommendations made in the audit report DG(SANTE)/2016-8784 regarding controls on

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pesticides in food of plant origin intended for export to the EU. The report of that audit
concluded that comprehensive measures had been adopted, which were expected to
progressively improve compliance with domestic and export market requirements. The
recommendations of report DG(SANTE)/2016-8784 are described in chapter 5.7 (Follow Up)
below.

According to data from the statistical office of the EU, Turkey was the fifth biggest exporter
of fruit to the EU (565,331 tonnes, excluding nuts and bananas) in 2017, of which 181,261
tonnes were citrus fruit (32 % of total fruit exports to the EU). In 2018, Turkey was the sixth
biggest exporter of fruit, with 661,542 tonnes, of which 284,764 tonnes (43 % of total fruit
exports) were citrus fruit.

With regard to vegetables, Turkey was the fifth biggest exporter to the EU in 2017, with
286,630 tonnes, and the fourth biggest exporter in 2018, with 345,875 tonnes. Of the total
vegetable exports to the EU, sweet peppers represented 19 % in 2017 (54,724 tonnes) and 18
% in 2018 (63,171 tonnes).

In 2018, 84 notifications were issued in the EU Rapid Alert System for Food and Feed
(RASFF) relating to pesticide residues in food imported from Turkey, of which 57 were
related to sweet peppers (67.9 % of the total number), 16 for citrus fruit, and seven for
pomegranates. In 2019 (as of 19 November), there were 74 RASFF notifications for produce
from Turkey, of which 51 were related to sweet peppers (68.9 % of the total number), eleven
were for citrus fruit (oranges and mandarins), and nine for pomegranates.

With regard to sweet peppers, four of the RASFF notifications in 2018 were related to
multiple residues, and three RASFF notifications identified pesticides not authorised in the
EU. Similarly, there were three cases in 2019, where multiple residues were found, and two
further cases, where pesticides, not authorised in the EU, were identified. The active
substances, most frequently found in sweet peppers from Turkey, include formetanate,
chlorpyrifos, acetamiprid, fosthiazate and methomyl (more relevant in 2018). The non-
approved active substances included carbendazim and omethoate. Of these, at the time of the
audit, carbendazim, and omethoate were not authorised for use in Turkey either, and
formetanate and methomyl were not authorised for use in sweet peppers.

For citrus fruit (oranges and mandarins), the active substance esfenvalerate was involved in
all 13 RASFF notifications in 2018 and 2019. At the time of the audit, esfenvalerate was
authorised for use in other crops, but not on oranges and mandarins.

With regard to pomegranates, eleven different active substances were involved in the RASFF
notifications in 2018 and 2019, mostly prochloraz, chlorpyrifos, acetamiprid, and the non-
approved in the EU omethoate. Of these, at the time of the audit, prochloraz was not
authorised for use in pomegranates, and omethoate was included in the list of active
substances banned in Turkey. In 2018, there were two cases of multiple residues, whereas in
2019, six cases (out of a total of nine, or 66.7 %) were related to multiple residues.

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The 2017 report of the European Food Safety Authority on pesticide residues in food
(https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2019.5743) indicated a non-
compliance rate of 8.1% in 2016 and 8.5% in 2017 for food imported from Turkey, which
was above the average non-compliance rate for produce imported from non-EU countries.

Due to the non-compliances identified in the EU for food imported from Turkey, Regulation
(EC) No 669/2009 established an increased rate of 10% physical checks at import for sweet
peppers, vine leaves and lemons. The number of RASFF notifications has decreased for vine
leaves and lemons. There were no notifications regarding pesticide residues in vine leaves in
both 2018 and 2019. For lemons, 12 notifications were issued in 2018, and no notifications in
2019 by the time of the audit. However, the number of RASFF notifications for sweet
peppers remained stable and still high in both, 2018 and 2019 (see above).

5 FINDINGS AND CONCLUSIONS

5.1 RELEVANT NATIONAL LEGISLATION

EU Legislation

Article 46(1)(a) of Regulation (EC) No 882/2004.

Findings

1. The national legislation in place within the scope of the audit has been described in
previous reports, including DG(SANTE) 2016-8784, 2013-6684 and 2011-6029.
2. Since the previous audit in 2016, the following pieces of legislation entered into force:
a. Regulation on the Authorisation of PPPs, entry into force on 9 November 2017
(Official Journal No.30235);
b. Implementing Regulation establishing a PPP Tracking System, entry into force on
13 February 2019 (Official Journal No. 30685);
c. Regulation on the storage of PPPs at wholesalers and retailers, entry into force 13
January 2019 (Official Journal No. 30685);
d. Implementing Regulation on the Importation of PPPs and Raw Materials Used in
the Production of PPPs, entry into force on 14 February 2019 (Official Journal
No. 30625);
e. Regulation on Maximum Residue Limits (MRLs) of Pesticides (Turkish Food
Codex Regulation, Official Journal No. 29899) takes into account Regulation
(EC) No. 396/2005 as amended by Regulation (EU) No. 2016/567 and was
published on 25/11/2016; the “Turkish Food Codex Regulation on MRLs of
Pesticides”, drafted based on this Regulation, provides guidance to the official
control officers and the pesticide residue laboratories in the provinces is publically
available at:

4
 https://www.tarimorman.gov.tr/GKGM/Belgeler/Mevzuat/Talimat/Pestisit_Rehbe
r.pdf .
Conclusion on relevant national legislation

3. National legislation is in place regulating aspects within the scope of this audit.

5.2 COMPETENT AUTHORITIES

EU Legislation

Articles 46(1)(b) and (c) of Regulation (EC) No 882/2004.

Findings

4. The CAs were described in previous audit reports, including DG(SANTE) 2016-8784,
2013-6684 and 2011-6029. There have been no changes since the previous audit.
5. Within the scope of the audit, it is the responsibility of district CAs and, in particular,
staff from the Plant Production and Plant Health Divisions, to implement pre-harvest
controls at growers and official controls on the marketing of PPPs at distributors. There
are 706 districts in Turkey, and a total of 3,400 inspectors all over the country, dealing
with those controls. Of these, 82 were allocated in the province of Mersin, and 125 in
the province of Antalya.
6. Post-harvest controls of fresh fruits and vegetables are carried out by the 7,004 food
inspectors from PFCDs and district CAs in all 81 provinces.
7. There is a good co-operation and communication between central, provincial and district
levels of the CA. This was shown in particular, in the follow-up to RASFF notifications,
and in the context of planning, implementation and co-ordination of official controls
within the scope of the audit.
Conclusion on competent authorities

8. The CAs and their responsibilities are clearly defined to allow adequate
implementation of the control systems regarding pesticides.

5.3 OFFICIAL CONTROLS OF THE MARKETING AND USE OF PLANT PROTECTION

PRODUCTS

EU Legislation

Articles 46(1)(e) and (b) of Regulation (EC) No 882/2004.

5
 Findings

5.3.1 Authorisation of Plant Protection Products

9. Authorisations are granted for chemical PPPs, bio-pesticides, biological control agents
and pheromone traps. At the time of the audit, there were 388 active substances
authorised in more than 5,000 PPPs in Turkey. Of the 388 active substances, 60 are
currently not approved in the EU. Of those, two have never been notified and assessed in
the EU, three are microorganisms, and two are plant oils. Some of the chemical
substances have been banned in the EU for many years. The GDFC stated that, since
2009, they had banned 185 active substances, which were determined harmful to human
health and the environment.
10. The PPP database is publically available on-line at: https://bku.tarim.gov.tr/, and a
mobile application has also been developed including information on authorised PPPs,
targeted pests, authorised uses (crops), application rates, PPPs recommended for
Integrated Pest Management (IPM) and products for biological and biotechnical
controls. The database is regularly updated.

5.3.2 Control of the marketing of Plant Protection Products

11. Marketing of PPPs is controlled according to Law No 5996, Regulation No 27939 on the
Control of PPPs and Regulation No 30685 on placing on the market, wholesale, retail
and storage of PPPs.
12. According to information provided by the CAs, at the time of the audit, there were 53
PPP manufacturers, 7,295 dealers of PPPs of which about 4,700 are wholesalers. These
are subject to control at least once a year. In the case of any non-compliance at farm
level, the relevant seller of PPPs is also visited, in particular where non-authorised PPPs
have been used.
13. The GDFC started to operate a PPP tracking system at the beginning of 2018. Machine
readable quick response codes are allocated to PPPs imported into and manufactured in
Turkey. Using specifically developed software, the aim of this system is to monitor the
volume of PPP sales, and eventually decrease the volume of PPPs used.
Representatives from GDFC stated that all wholesalers and 50-60% of retailers were
using this system at the time of the audit.
14. Quality control analysis of PPPs is carried out by the Pesticide Control Laboratory at
the Pest Control Central Research Institute in Ankara, and the Pesticide Control
Laboratory in Istanbul.

5.3.3 Control of users of Plant Protection Products

15. According to data provided by the MAF, there are around 3 Mio growers in Turkey, and
the vast majority of these are small-scale producers. As of 2005, there is a system for
registration of growers with the MAF. However, this is not a legal obligation, but a
voluntary choice of producers. At the time of the audit, there were 37,650 growers

6
 registered with the MAF, in the province of Mersin, and 40,222 in the province of
Antalya. In addition, a further 74,000 operators (including crop-growing, animal and
aquaculture farms) in the province of Mersin and 137,644 in the province of Antalya
were registered with the Agricultural Chambers. Some of the operators could be
registered with both in parallel.
16. Official controls for pesticide residues in Turkey are performed in accordance with an
annual control programme. The central CA (MAF) is drafting the annual control
programmes, covering both pre- and post-harvest stages. Provincial and district CAs
provide input to the planning, mainly with regard to crops to be covered. Controls at
growers (primary production stage) are covered by the pre-harvest part of the
programme.
17. According to information provided by the CA, the annual control programme is risk-
based, where the main criteria are the following: previous non-compliances for both
domestic and exported produce, total area of crops covered and production volumes,
level of infestation by particular pests requiring chemical control and potential exports to
EU and/or non-EU countries. Documentary evidence was provided to the audit team to
confirm this approach (i.e. active substances and commodities, involved in RASFF
notifications, were included in the list of analytes sought by the official laboratories, and
the list of crops to be sampled).
18. The annual programmes cover all 81 provinces, list the crops to be covered, the number
of samples to be taken (break-down per province), the official laboratories to be used for
analysis of samples taken, and these contain further instructions for inspectors, including
sampling instructions and further technical instructions for staff from the provincial and
district CAs. It was highlighted by the CAs that pre-harvest inspections are mainly
focused on fresh fruit and vegetable production.
19. In accordance with information provided by both the central CA and the two provincial
CAs met by the audit team, pre-harvest inspections focus on pre-harvest sampling for
pesticide residues. These inspections are also used as an opportunity for the relevant
CAs to provide technical support, advice and training to growers visited. Although it
was stated by the CAs that pre-harvest inspections also include controls on PPP use, in
addition to sampling, it was highlighted that the main aim is to further educate and
support farmers rather than perform in-depth controls.
20. As a follow-up to recommendations from previous audits, standard check-lists were
developed for official controls on the use of PPPs (at primary production). These were
well known and available to inspectors in both provinces visited. However, these are
quite simplified, and do not describe in details all the aspects to be covered during the
inspection. They cover rather more general topics, including the following: IPM
(implemented or not), bio-control methods (used or not); records on PPP use (available
or not); PPP purchased (prescribed by an authorised advisor or not); PPP application (by
a certified operators or a service-provider); comment box (to describe any further issues
found during inspections, if any). Moreover, pre-harvest controls are limited to sampling

7
 for pesticide residues. Additional controls, following the standard check-list, were seen
to take place only in the case of follow-up to non-compliances.
21. According to data provided by the relevant CA, the number of pre-harvest controls
increased from 14,396 in 2016 to 18,036 in 2018. The CAs explained the increase of
pre-harvest samples analysed with expanding the laboratory capacity (new instruments
purchased for official laboratories), as well as their intention to extend the coverage of
operators.
22. In 2018, the annual control programme covered 43 different crops, including oranges,
mandarins, lemons, sweet peppers and pomegranates.
23. In 2018, 1,419 samples were taken as part of the pre-harvest control in the province of
Mersin. Of the total number of samples, 310 were taken from citrus fruit (21,8 % of the
total), 180 from sweet peppers and 46 from pomegranates.
24. In the case of citrus fruit, 41 non-compliances were identified, representing 13.2 % of
the total number of samples taken, which is a high non-compliance rate. Three of the
non-compliant cases were related to MRL exceedances, and 38 were detections of non-
authorised PPPs used or non-authorised uses of PPPs (12 % of the samples).
Chlorpyrifos was one of the seven active substances detected, which was a non-
authorised use in citrus fruit (oranges, mandarins and lemons).
25. With regard to pomegranates, one sample was found to contain residues of acetamiprid
above the national MRL. For sweet peppers, no non-compliances were identified.
26. In the same period (2018), 3,273 pre-harvest samples were taken in the province of
Antalya, of which 1,400 from sweet peppers (42.8 % of the total), 937 from citrus fruit,
and 90 from pomegranates.
27. In the case of sweet peppers, 120 non-compliances were identified (8.6 % of the total
samples), of which the vast majority (82 cases) were related to MRL exceedances, and
the remaining 38 were cases of either non-authorised uses or use of non-authorised
pesticides. Similarly to findings in the EU (see Chapter 4 above), formetanate and
chlorpyrifos were amongst the active substances, most frequently found. These were not
authorised for use in sweet peppers in Turkey.
28. With regard to citrus fruit, the average non-compliance rate was 10.4 %. For oranges
and mandarins in particular, there were 26 cases (out of a total of 263) of non-authorised
uses of chlorpyrifos and pyriproxifen.
29. For pomegranates, the non-compliance rate identified was also quite high, where 21
samples (23 % of the total) were found to exceed the national MRLs.
30. In addition to pre-harvest controls, further controls on the use of PPPs are performed by
the district CAs, mainly through checks of records on PPP application. In 2018, 5,427
such checks were performed in the province of Mersin, and 6,933 in the province of
Antalya.

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31. With regard to primary production, there is a number of projects on-going, including the
following:
 An IPM project, which has been running for several years, where coverage was
extended to cover all 81 provinces; initially, the IPM project covered 16 crops
(grapes, apples, apricots, cherries, greenhouse vegetable production (tomatoes,
eggplants, sweet peppers and cucumbers), peaches, citrus fruits, olives, hazelnuts,
pistachios, cotton, chickpea, maize, lentils, potatoes and wheat), and six further crops
were included more recently, including pears, quinces, pomegranates, rice, walnuts
and sour cherries; the CAs stated that their intentions are to add five further crops by
2023;
 Since the last audit in 2016, the Integrated and Controlled Product Management
(EKÜY) programme was extended from covering 36 to 50 provinces at the time of the
current audit, resulting in an increase of the number of growers involved and the total
area covered; in order to facilitate growers in IPM implementation, the MAF, in co-
operation with Research Institutes, have developed IPM Technical Instructions for the
22 crops listed above, which are publicly available on the MAF web-site
(https://www.tarimorman.gov.tr/Konu/921/Entegre_Mucadele), and regularly up-
dated, in particular with regard to PPPs authorised; in 2018, the programme covered
38,028 of growers, and a total area of 339,200 hectares (ha); in the province of
Mersin, 2,548 growers were involved in the programme, with a total production area
of 1,120 ha, and in the province of Antalya, 1,752 growers and production area of
2,862 ha;
 The project for support of biological control and bio-techniques is still on-going; in
2018, the project covered 14 crops, 11,741 growers and a total production area of
31,900 ha, aiming at providing both financial and methodological support to growers
involved; with regard to citrus production, the project covers a total of 1,416 growers
in 10 different provinces, and an area of 7,240 ha; in the case of pomegranates, 32
growers from two provinces are involved in the project, with a total area of 94 ha,
where the lower coverage of pomegranate production was explained by the CAs with
the limited options available for biological control in this crop; greenhouse
production of vegetables (pepper and tomato) is also covered by the project, including
4,170 growers and 2,700 ha production area;
 Following the initiative of the government from 2015 to provide interest-free loans to
vegetable producers for the modernisation of greenhouses, facilitating the use of IPM
and the effective use of biological control, based on a decision of the Council of
Ministers from 2018, the amount was increased from 100,000 Turkish Liras
(approximately 31,000 Euros) to 300,000 Turkish Lira (approximately 45,000 Euros).
However, despite the progress made in this regard, the coverage of operators and
production areas under all these initiatives remains low, compared to the total number of
operators and total area for growing crops.

9
32. Regulation No 29194 of 3 December 2014 on recommendation, application and
registration procedures of PPPs provides for PPP purchases to be based on prescription
by authorised advisors, PPPs to be applied only by certified operators and records on
PPP application to be kept. Records on PPP use are standardised, providing reference to
the number of individual plots treated, and containing information on the PPP
prescribed, the active substance contained and the application rate, the targeted pest,
date of application, date of harvest, purchase at a licensed PPP dealer (verified by
signatures of the authorised advisor, licensed PPP dealer and the operator, who
performed the application). The standard records were seen to be used by all growers
visited during the audit.
33. At the time of the audit, there were 17,110 advisors authorised to prescribe PPPs in
Turkey. Of those, 10.1 % were located in the province of Antalya, and 4.2 % in the
province of Mersin. At the same time, a total of 469,953 operators were certified to
apply PPPs, of which 10.5 % in the province of Antalya, and 6.6 % in the province of
Mersin.
34. There are clear requirements in place for authorisation of advisors and certification of
operators applying PPPs. However, there is no period of validity for either of these. On-
going training to keep operators up-to-date in their areas of competence, once every two
years, is a requirement only for the advisors. None of the growers visited had ever
attended a refreshment course after the initial training for the purposes of certification,
where the duration of the initial training sessions is six hours. Although Regulation No
29194 contains provisions for withdrawal of authorisations and/or certificates, there
have been no such cases so far. Moreover, once the authorisations and/or certifications
are granted by the MAF, there is no further supervision to confirm that both categories
of operators continue to meet the requirements, as per national legislation.
35. A uniform approach was seen to be followed in the case of non-compliances identified
during pre-harvest controls, including imposing sanctions and fines to growers. In the
case of MRL exceedances, in particular, the growers were advised, verbally, to postpone
harvesting. This is a reasonable measure in the case of pomegranates, where harvesting
is performed at once, within a limited period. However, in the case of sweet peppers, the
harvesting period is extended to up to three months. Thus, results from pre-harvest
sampling in this case are not useful for drawing conclusions on general compliance or
non-compliance of the growers.
36. Three growers were visited by the audit team, who were involved in RASFF
notifications, and documentary evidence was seen in the context of RASFF follow-up in
several more cases. Although there were no deviations from the procedures in place,
only one case was seen, where the investigation identified the root cause of the
contamination. Moreover, there were no sanctions or fines imposed to growers, involved
in RASFF notifications, because the findings were not the result of an official pre-
harvest control/sampling. Corrective measures were usually required verbally, with no
follow-up inspections to confirm, that these have been implemented. Non-compliant

10
 growers were scheduled for a regular surveillance in the following season, but focusing
again on providing methodological support and training.
Conclusions on official controls of marketing and use of Plant Protection Products

37. The official controls in place regarding marketing of PPPs aim at ensuring that only
authorised PPPs are placed on the market and applied by PPP professional users. The
new legislation adopted and the tracking system introduced recently have the potential
to detect illegal PPPs. However, the high non-compliance rate identified at the pre-
harvest stage for certain crops and, in particular, the use of non-authorised PPPs,
which is a confirmation that effectiveness of controls at pesticide distributors needs
further improvement.
38. Despite the efforts made by the CAs to strengthen controls at farm level, Turkish
produce continuously breaches EU MRLs, often with multiple residues, with the same
pesticides being repeatedly detected by EU MSs, some of which are neither approved
in the EU nor in Turkey. This is mirrored by the results of the national control
programme. These both indicate the systematic failure to ensure that only authorised
PPPs are used, following good agricultural practices and PPP labelling, thus providing
assurances that the final produce will comply with EU MRLs. These weaknesses
undermine the effectiveness of official controls of PPP use, although a lot of efforts
and resources have been allocated for this task.

5.4 OFFICIAL CONTROLS OF PESTICIDES RESIDUES IN FOOD OF PLANT ORIGIN

EU Legislation and standards

Articles 46(1)(a), (b), (c), (d), (e) and (h) of Regulation (EC) No 882/2004;
Article 11 of Regulation (EC) No 178/2002;
Article 18 of Regulation (EC) No 396/2005;
Commission Directive 2002/63/EC;
Codex MRLs for Pesticides;
CAC Guidelines 33-1999;
CAC Guidelines 26-1997;
CAC Guidelines 27-1997;
CAC Guidelines 90-2017.

Findings

5.4.1 Post-harvest control for pesticide residues

39. Post-harvest controls of fresh fruits and vegetables are carried out in accordance with the
annual control programme, described under chapter 5.3.3 above (see paragraphs 16, 17
and 18).
40. In total, 2,523 post-harvest samples were taken in 2016, 2,950 samples in 2017 and
3,354 in 2018 in Turkey. In addition to the planned post-harvest samples, samples can

11
 be taken in response to complaints and to follow up on RASFF notifications (see chapter
5.5), as well as based on identified additional risks.
41. The post-harvest controls cover food hygiene related aspects, some traceability checks
and sampling. Samples are taken at wholesalers, pack houses and retailers. The sampling
method for official controls of pesticide residues was stated to be in line with Directive
2002/63/EC. Similarly to non-compliances identified in the pre-harvest stage (see
paragraphs 35 and 36), sanctions can be imposed in the post-harvest period, where the
analytical results show exceedance of national MRLs, the use of non-authorised PPPs
and/or non-authorised uses of authorised PPPs.
42. In Mersin province, 224 fruit and vegetable samples were taken in 2017, with 11 non-
compliant samples identified, 289 samples in 2018, with 4 non-compliant cases and 194
samples in 2019 (by the time of the audit), with 5 non-compliances identified. The non-
compliance rate throughout the period between 2017 and 2019 varied between 1.4 %
and 4.9 %.
43. In Antalya province, 283 fruit and vegetable samples were taken in 2017 with 39 non-
compliant samples identified, in 2018, 398 samples were taken with 61 non-compliant
cases and by the time of the audit in 2019, 327 samples were taken and 45 non-
compliant cases have been identified. These data indicate a stable, high non-compliance
rate of 13.8 %, with an increase up to 15.3 % in 2018.
44. The number of samples taken in the post-harvest stage in 2018, was five times lower, in
the province of Mersin, and eight times lower, in the province of Antalya, compared to
the number of samples taken for pesticide residues at primary production level (see
paragraphs 23 and 26). In this way, official controls focus on the first stage in the food
chain, whereas further PPP applications could be carried out or cross-contaminations
could occur in the later stages, including processing, storage and transport (see
paragraph 58).
45. According to Article 22 (4) of Regulation No 29194 (see paragraph 27 above), food
business operators (FBOs) have to keep records on post-harvest uses of PPPs. However,
the GDFC confirmed that these are not subject controls. One of the exporters visited has
decided only recently to record post-harvest uses of PPPs, in response to a RASFF
notification, which was his own initiative. Although records were available, these were
not checked by the inspectors, because this aspect does not fall within the scope of
inspection, and the standard check-list does not require for this either. The other two
exporters visited did not keep such records.
46. There are no requirements for FBOs to arrange for sampling and analysis, which would
ensure equivalence with the provisions laid down in Article 4 (3) (e) of Regulation (EC)
No 852/2004, in conjunction with Article 10 of the same Regulation. Only one of the
exporters visited has recently started to take samples for the purposes of their own
controls, following the involvement in a RASFF notification. However, similarly to the
approach described under paragraph 38 above, these were neither checked by the
inspectors, nor were an aspect covered in the standard check-list.

12
47. According to information provided by the Exporters associations met during the audit,
sampling and analysis for the purposes of exporters' own controls are rather based on
projects, running for a limited period of time, than a common practice.
48. Prochloraz in pomegranates has been found repeatedly in the EU (see chapter 4 above).
It is not authorised for use in or on pomegranates, but is authorised for post-harvest use
on oranges, and also for disinfection of empty premises, i.e. warehouses. However,
investigations in response to RASFF notifications, related to prochloraz in
pomegranates, have never identified the source of contamination.

5.4.2 Control at Exporters

49. All pack-houses, food processors, and exporters are required to be registered as FBOs
with the MAF under Law No 5996. All operators, visited by the audit team, were
registered FBOs.
50. Before a consignment of plants or plant products is exported, an export application has
to be submitted to the relevant provincial or district CA. The application includes a list
of fields where the commodity was harvested from and a copy of records of PPPs used
during the growing season. Where a phytosanitary certificate is required, the records are
checked and stamped by the plant health inspector. The CAs stated that they check
whether the PPPs used are authorised in Turkey, and whether the PPPs are authorised
for this crop.
51. For the purposes of pre-export controls, there is a fixed frequency of 10 % with regard to
sampling for lemons, vine leaves and sweet peppers. This frequency is the same as the
one specified in Regulation (EC) No 669/2009 for the same commodities. The analytical
scope for analysis of sweet peppers included all eleven active substances, as required by
the same Regulation, as well as all pesticides involved in RASFF notifications
repeatedly throughout the years.
52. For all the other commodities, there is no fixed frequency for sampling, and the CAs
were of the opinion that these commodities are sufficiently covered under the national
control programme, thus providing sufficient guarantees that, in the case of export, there
would be no findings of pesticide residues. The CAs stated that oranges, mandarins and
pomegranates can be selected for control/sampling prior to export, based on risks, if any
have been identified.
53. Since 2016, a total of 1,714 sweet pepper samples have been taken and analysed for
pesticide residues, and only 2 non-compliant samples have been identified, both in 2016.
As a comparison, the EU MSs issued 57 RASFF notifications in 2018 alone, and 51
notifications between 01 January and 19 November 2019.
54. Exporters source their produce from dealers (intermediaries) or directly from growers.
Another scenario is to get supplies directly from growers, based on verbal agreements,
or less commonly, based on written contracts. However, there are no clear requirements
for suppliers, and no specific requirements with regard to PPP use either. The main
focus is on the volumes and quality of the produce. Exporters or their representatives do

13
 not perform any checks at or provide any advice to suppliers during the growing season.
Growers are visited before the start of harvesting, mainly to check the quality of the
produce and confirm that the volumes agreed could be delivered.
55. The GDFC stated that activities of intermediaries are regulated by Law No 5957 (entry
into force 26/3/2010; Official Journal No 27533), which requires them to be registered
with the Ministry of Trade. Following their registration with the Ministry of Trade, they
have also the obligation to register with the GDFC, through the on-line Food Safety
Information System of the MAF. Once in the system, these operators shall be subject to
official controls according to the Law No 5996 (Food Law). However, this was not a
practice in either of the provinces visited. Moreover, at meetings in the course of the
audit, it was stated on several occasions that intermediaries are not considered FBOs,
and these could be subject to control only by the Ministry of Trade.
56. Exporters, as they are considered FBOs under the Food Law, are required to have
traceability systems in place, allowing tracing the produce back to the grower level. The
exporters met by the audit team were able to trace back the exported produce to farm
level, based only on receipt issued. However, they did not have a system in place to
identify batches from receipt of the produce, trace it throughout the packaging process
and to the final consignment, thus not allowing for full traceability. For this reason, as
well as the improper or lacking labelling of produce at the time of delivery at exporters,
there was a high probability of mixing produce from various growers.
57. Traceability throughout the whole chain, from growers to exporters, is impossible
because of the lack of requirements for intermediaries to have a traceability system in
place, and the lack of official food safety controls by the relevant PFCDs at these
operators.
58. Pesticide residues can be the result of disinfection of storage facilities, empty premises
and/or means of transport. The CAs stated that these treatments are usually biocidal
uses, which fall within the responsibility of the Ministry of Health. Discussions during
the audit made it clear, that these treatments have never been considered as a potential
source of contamination or MRL exceedances, either by the CAs or by the exporters. In
addition, these have never been covered during official controls by the PFCDs, as they
are regulated and controlled by a different CA. Under the Food Law, vehicles or any
other means of transport, used by FBOs, shall meet specific hygiene conditions, and
these have to be subject to verification during official controls. However, none of the
inspections observed covered this aspect.
59. The exporters visited, who were also involved in RASFF notifications, stated that in the
cases where they are made aware that growers supplying to them are involved in RASFF
notifications they stop purchasing their produce.

5.4.3 Laboratories for Pesticide Residue Analysis

Laboratory network

14
60. There is a laboratory network for pesticide residue analyses, which includes 19 officially
designated public food control laboratories, sub-ordinated to the MAF, and 27 private
laboratories approved for the same tasks by the MAF. All laboratories from the network
are subject to audits by the MAF, and their work is coordinated by the National
Reference Laboratory (NRL) in Ankara.
61. There are clear criteria for designation and/or approval of laboratories, one of which is
the analytical scope covered. At the time of the audit, all laboratories from the network
were required to analyse for 329 active substances, whereas the total number of those
authorised at the time of the audit was 388. The list of analytes to be sought is up-dated
on an annual basis, and the list of 329 included all of the pesticides, involved in RASFF
notifications in 2018 and 2019.
Laboratories visited

62. The audit team visited a private laboratory performing pesticide residue analysis in
Mersin and the official Food Control Laboratory in Antalya.
Private Laboratory, Mersin

63. The laboratory was approved by the MAF to analyse pesticide residues in food. The
laboratory has been accredited according to International Standards Organisation (ISO)
17025 by the Turkish accreditation body (TÜRKAK) since 2011. The samples analysed
at the laboratory come from the private sector, as well as official samples for the
purposes of import / export controls.
64. The laboratory was staffed with three analysts, dealing with pesticide residue analysis.
The staff were well competent and qualified. Introductory and on-going training of staff,
relevant for their area of competence, was in place. The laboratory had excellent
facilities and state-of-the-art instrumentation comprising LC-MS/MS, GC-MS/MS and
GC-MS-headspace.
65. The analytical method used is QuEChERS multi-residue method (MRM), covering 665
active substances. In the case of analysis of official samples, the number of analytes
sought is 329. Single Residues Method (SRMs) were used for determination of
dithiocarbamates, propylenethiourea, propineb and thiram. The validation of a method
for analysis of polar compounds was in progress at the time of the audit.
66. The Guidance document on analytical quality control and method validation procedures
for pesticide residues and analysis in food and feed (SANTE/11813/2017) was translated
in Turkish by the MAF and followed by the laboratory. The analytical methods in use
were validated, and the limit of quantification (LOQ) for most of the analytes were set at
0.01mg/kg.
67. The audit team reviewed a non-compliant sample of lemon, starting from sample
reception to issuing the analytical report. There was a good traceability, and the quality
criteria, as per SANTE guidance document, were followed, including the calibration for
all analytes in the batch, matrix matched multi-level calibration, bracketing calibration
and the quality control sample. The stability of standards was checked properly. The

15
 measurement uncertainty of +/- 50 % was applied by the laboratory, and was included in
the analytical report.
68. The laboratory had participated in several Proficiency Tests (PTs) organised by the Food
Analysis Performance Assessment Scheme (FAPAS), as well as in inter-laboratory tests
organised by the NRL, with good results. The laboratory has never participated or
considered to take part in PTs organised by any of the EU Reference Laboratories.
Official Food Control Laboratory, Antalya
69. The laboratory performs analysis of samples taken for the purposes of official controls,
covering a variety of residues and contaminants. The laboratory has been accredited
according to ISO 17025 by TÜRKAK since 2006.
70. There were seven staff members, involved in pesticide residue analysis, with different
academic degrees. The staff was qualified and competent. The laboratory had excellent
facilities and modern equipment, comprising LC-MS/MS, GC-MS/MS, HRAMS-LC,
HRAMS-IC, GC-MS-headspace, HPLC-GPC.
71. A broad range of multi residue method and single residue methods are in place. The
scope covered by the QuEChERS MRM included 329 active substances using LC-
MS/MS and GC –MS/MS. The HRAMS-LC method used covered 380 analytes, with
some overlapping of analytes included also in the LC-MS/MS scope. In addition, SRMs
were used for determination of dithiocarbamates, biphenyl and polar pesticides.
72. The methods were validated according to the SANTE guidance document, and the LOQ
was set at 0.01 mg/kg in most cases. The quality control sample and the multi-level
calibration were used in the batch, but not bracketing standards. The least could affect
the quality of the measurements due to the drift of the detection system, especially when
the number of samples in the batch was large.
73. The multi-level calibration in tomato matrix was used for quantification of the lemon
sample. However, possible matrix effects were not studied or considered, which could
cause underestimation of the results in particular, with regard to determination of citrus
fruits by using the LC-MS/MS technique. This could affect reliability of analytical
results. Furthermore, the LOQ of carbofuran was validated at 0.01 mg/kg for the
commodity group of high water content, and high acid and high water content.
However, for carbofuran and any carbofuran generated substances, the MRL is set to
0.001-0.002 mg/kg in commodities with high water content.
74. The traceability of a non-compliant sample of lemon was reviewed, from reception to
reporting the results. Each sample had a unique laboratory number resulting in full
traceability. Measurement of uncertainty of +/- 50% was taken into account and
included in the analytical report.
75. The laboratory had participated, with good results, in a high number of relevant PTs,
organised by FAPAS and the NRL, in a range of validated commodity groups.
Participation in EU Reference Laboratory PTs has never been considered.

16
Conclusions on official controls of pesticide residues in food of plant origin

76. The lack of controls of PPP post-harvest treatments, of full traceability throughout the
food chain, and of requirements for FBOs to implement own controls, as well as not
considering possible biocidal uses in empty storages and means of transport as the
potential cause of MRL exceedances compromise the effectiveness of the control
system. Moreover, the lesser priority given to controls in the post-harvest stage does
not allow for providing better assurance that the final products would meet the EU
requirements.
77. Exporters own controls for pesticide residues are either lacking or very limited. These
are not aiming at preventing non-compliances, but are rather undertaken in response
to non-compliances identified during domestic official controls or in the EU. Thus, the
responsibility on ensuring compliance with EU MRLs in the case of export is left
solely with the authorities, who also fail in providing sufficient assurance.
78. The official laboratories visited have adequate premises, modern equipment,
experienced and knowledgeable staff, so as to deliver good results, thus contributing
to the effectiveness of official controls of pesticide residues. However, the current
analytical scope in official laboratories does not cover all pesticides authorised for use
in the country. This, together with some weaknesses identified in one of the
laboratories, can undermine the reliability of analytical results, and does not provide
sufficient guarantees that EU MRLs would be complied with, and no illegal pesticides
have been used.

5.5 RESPONSE TO RASFF NOTIFICATIONS

Standards

Point 6 of the CODEX Guidelines CAC/GL 25-1997.

Findings

79. The GDFC issued an instruction for follow up of RASFF notifications, which was last
updated in September 2019. Two national RASFF contact points have been identified at
the DGFC who forward the RASFF notification to the relevant PFCD. The PFCD
informs the district authorities, who carry out an inspection at the exporter involved and,
where the grower has been identified, an inspection at farm level as well.
80. The follow-up inspections include traceability and hygiene checks. If the commodity in
question is still available, then samples are taken and sent for laboratory analyses.
81. As of September 2019, there was a decision for sampling of the following five
consignments, where a RASFF notification has been issued for produce originating in
Turkey. This five-consignment rule should be applied at non-compliant operators, for
the same commodity. Written instructions were drafted by the central CA and circulated
to provincial and district authorities. If the results show non-compliance, the five-

17
 sampling rule is re-launched. This practice had been applied for sweet peppers since 14
June 2016.
82. The time lapse between the release of the RASFF notification and follow-up inspections
generally took two months, which is too long to take rapid actions to remedy the
situation. Two RASFF National Contact Points were designated as of August 2019
aiming to act more quickly and work more efficiently. In addition, investigations in
response to RASFF notifications did not identify the source of contamination in most of
the cases. Further details are provided in previous chapters (see paragraphs 36, 45 and
48).
Conclusions on response to RASFF notifications
83. Written procedures are in place for the follow-up on RASFF notifications, and these
are systematically implemented. However, actions taken in response to RASFF
notifications are usually delayed and, in the vast majority of cases, the root causes are
usually not identified, which hampers their effectiveness.

5.6 PRIVATE CONTROLS ON FRUITS AND VEGETABLES EXPORTED TO THE EU

EU Legislation

Article 10 of Regulation (EC) No 852/2004, in conjunction with Article 3 of the same

Regulation.

Findings

84. The audit team met two exporters associations. The exporters association, based in the
first province visited, had 413 members. They developed a "passport system" to ensure
that producers follow the requirements for quality and safety of produce. The passport
system requires members, who join the system, to work with contracted growers, record
plant protection measures applied, including PPP uses, and implement IPM principles.
The exporter visited in the region was in the process of joining the passport system.
85. The exporters association, located in the second province visited, had 192 members, all
of which were exporting to the EU. About 25% of the exporters in the three provinces
covered were members. The association recommends to their members to use contracted
farmers, apply IPM principles and reduce the use of chemical PPPs. They run a project,
under which 200 samples for pesticide residues were taken from tomatoes, sweet
peppers, zucchini and eggplant. Of the total, only two samples were found to be non-
compliant.
86. Both exporters associations organise regular training sessions and meetings for growers
and other stakeholders, which cover different topics, among which plant protection
measures, IPM and measures to apply in order to prevent pesticide residues in the final
products.

18
87. Out of the three growers visited, only one was certified according to an international
private Good Agricultural Practice scheme. Certification according to private schemes is
not a common practice among growers exporting to the EU, but rather an exception.

Conclusions on private controls of fruits, vegetables and herbs exported to the EU

88. Very limited private controls are in place, which are rather project based than a
common practice, thus not at all or not sufficiently contributing towards addressing
the non-compliances found in the EU in the case of exports from Turkey.

5.7 FOLLOW UP

The table below summarises the follow-up to the relevant recommendations made in report
DG(SANTE)/2016-8784:

No Previous recommendation Assessment

1 Ensure that the levels of pesticide residues in sweet Satisfactorily addressed,

peppers, cucumbers and vine leaves, intended for except for sweet peppers.
export to the EU comply with EU standards as laid
down in Regulation (EC) No 396/2005. This could be
achieved by continued support of Integrated Pest
Management measures, including biological control
and comprehensive record keeping of pesticide uses,
in particular by cucumber growers.

Conclusions upon which this recommendation is

based: 26, 35, 46.
Associated findings upon which this recommendation
is based: 8, 9, 11, 21, 22, 31, 32, 36, 37.
2 Ensure that the levels of pesticide residues in lemons, Satisfactorily addressed.
intended for export to the EU comply with EU
standards as laid down in Regulation (EC) No
396/2005. The source of the contamination of lemons
with biphenyl should be further investigated and
identified, to allow its effective control.

Conclusion upon which this recommendation is

based:53
Associated finding upon which this recommendation
is based:51

19
No Previous recommendation Assessment

3 Ensure that food business operators, carrying out any Not addressed, as there is no
stage of production or distribution of sweet peppers legal requirement for food
business operators to adopt
and cucumbers for export to the EU, adopt measures
measures for sampling and
for sampling and analysis, as appropriate, that are at analysis.
least equivalent to those required by Article 4 (3) (e)
of Regulation (EC) No 852/2004 in conjunction with
Article 10 of the same Regulation.

Conclusion upon which this recommendation is

based:58
Associated findings upon which this recommendation
is based:55, 56

20
Conclusions on follow-up

89. Two recommendations have been satisfactorily addressed, and one recommendation
had not yet been addressed at the time of the audit.

6 OVERALL CONCLUSIONS

Overall, the authorities have adopted a number of measures to help meet the EU
requirements with regard to pesticide residues in food, and to improve the effectiveness of
pesticide controls. These include initiatives to implement IPM principles and/or bio-control
methods, training of growers and advisors, extending the pre- and post-harvest sampling,
export controls and systematic follow-up of RASFF notifications. However, these have had
very limited impact so far.

The effectiveness of the system is compromised, in particular, by the inadequate training

and authorisation/certification of advisors and growers applying PPPs, by the limited
controls on PPP use at farm level, and the insufficient controls at pack houses and
exporters, mainly due to inadequate traceability of produce throughout the food chain, the
lack of legal requirements to record post-harvest PPP treatments, and not covering aspects
related to potential chemical treatments of empty storage facilities and means of transport.

Moreover, most of the efforts and resources for official controls come quite early in the
food chain, putting the emphasis in the pre-harvest stage, rather than in the post-harvest
period, which does not allow for providing better assurance that the final products would
meet the EU requirements.

Investigations in response to RASFF notifications not being able to identify the root causes
and the lack of or very limited own controls by FBOs raise further concerns with regard to
ensuring compliance with EU standards.

7 CLOSING MEETING

A closing meeting was held on 28 November 2019 with representatives of the relevant CAs.
At this meeting, the audit team presented the main findings and preliminary conclusions of
the audit. The CAs offered initial comments on the findings and conclusions presented.

8 RECOMMENDATIONS

The CA is invited to provide details of the actions taken and planned, including deadlines for
their completion ("action plan"), aimed at addressing the recommendation set out below,
within 25 working days of receipt of this report. The CA should:

No. Recommendation

1. Ensure that the levels of pesticide residues in produce from Turkey, intended for export

21
No. Recommendation
to the EU, comply with EU standards as laid down in Regulation (EC) No 396/2005.

Conclusions upon which this recommendation is based: 38, 76

Associated findings upon which this recommendation is based: 23, 24, 26 to 29, 34 to
36, 43 to 46, 48, 53 to 56, 58

2. Ensure traceability throughout the food chain in line with Article 18 of Regulation (EC)
No 178/2002.

Conclusions upon which this recommendation is based: 76

Associated findings upon which this recommendation is based: 56, 57

3. Ensure that FBOs, carrying out any stage of production or distribution of produce for
export to the EU, adopt measures for sampling and analysis, as appropriate, that are at
least equivalent to those required by Article 4 (3) (e) of Regulation (EC) No 852/2004 in
conjunction with Article 10 of the same Regulation.

Conclusions upon which this recommendation is based: 76, 77

Associated findings upon which this recommendation is based: 46, 47, 85

4. Ensure that RASFF notifications are followed up rapidly and effectively to ensure
compliance with EU standards as laid down in Regulation (EC) No 396/2005.

Conclusions upon which this recommendation is based: 83

Associated findings upon which this recommendation is based: 82

5. Ensure that samples of produce for export to the EU are analysed in laboratories with
sufficient scope to achieve effective controls of MRLs laid down in Regulation (EC) No
396/2005.

Conclusions upon which this recommendation is based: 78

Associated findings upon which this recommendation is based: 61, 65, 71

The competent authority's response to the recommendations can be found at:

http://ec.europa.eu/food/audits-analysis/rep_details_en.cfm?rep_inspection_ref=2019-6727

22
ANNEX 1 – LEGAL REFERENCES

Legal Reference Official Journal Title

Reg. 178/2002 OJ L 31, 1.2.2002, p. Regulation (EC) No 178/2002 of the
1-24 European Parliament and of the Council of
28 January 2002 laying down the general
principles and requirements of food law,
establishing the European Food Safety
Authority and laying down procedures in
matters of food safety

Reg. 882/2004 OJ L 165, 30.4.2004, Regulation (EC) No 882/2004 of the

p. 1, Corrected and European Parliament and of the Council of
re-published in OJ L 29 April 2004 on official controls performed
191, 28.5.2004, p. 1 to ensure the verification of compliance with
feed and food law, animal health and animal
welfare rules

Reg. 396/2005 OJ L 70, 16.3.2005, Regulation (EC) No 396/2005 of the

p. 1-16 European Parliament and of the Council of
23 February 2005 on maximum residue
levels of pesticides in or on food and feed of
plant and animal origin and amending
Council Directive 91/414/EEC

Dir. 2002/63/EC OJ L 187, 16.7.2002, Commission Directive 2002/63/EC of 11

p. 30-43 July 2002 establishing Community methods
of sampling for the official control of
pesticide residues in and on products of plant
and animal origin and repealing Directive
79/700/EEC
Annex 2 – Standards and Guidelines quoted in the report

Reference number Full title Publication details

CODEX MRLs CODEX Alimentarius International http://www.fao.org/fao-who-
Food Standards – pesticide MRLs codexalimentarius/codex-
texts/dbs/pestres/en/
Guidelines of Guidelines for the exchange of http://www.fao.org/fao-who-
CODEX CAC/GL 25- information between countries on codexalimentarius/codex-
1997 rejections of imported food texts/guidelines/en/
Guidelines of Guidelines for the Design, Operation, http://www.fao.org/fao-who-
CODEX CAC/GL 26- Assessment and Accreditation of Food codexalimentarius/codex-
1997 Import and Export Inspection and texts/guidelines/en/
Certification Systems
Guidelines of Guidelines for the Assessment of the http://www.fao.org/fao-who-
CODEX CAC/GL 27- Competence of Testing Laboratories codexalimentarius/codex-
1997 Involved in the Import and Export texts/guidelines/en/
Control of Food
Guidelines of Recommended Methods of Sampling http://www.fao.org/fao-who-
CODEX CAC/GL 33- for the Determination of Pesticide codexalimentarius/codex-
1999 Residues for Compliance with MRLs texts/guidelines/en/
Guidelines of Guidelines on Performance Criteria for http://www.fao.org/fao-who-
CODEX CAC/GL 90- Methods of Analysis for the codexalimentarius/thematic-
2017 Determination of Pesticide Residues in areas/pesticides/en/
Food and Feed