Integrity Report 2020
Efficient and fair response system
Complaint investigation procedure explained
Complaints received by GLOBALG.A.P. are recorded, analyzed, and investigated by a dedicated complaints management officer. Reports regarding a breach of standard requirements by GLOBALG.A.P. system users – including those related to Maximum Residue Limits (MRL) – can be raised via a complaint form on the GLOBALG.A.P. website. Complaints may also be received directly from stakeholders or the media.
If potential non-compliance of the standard requirements by a certified producer, producer group, or company is detected, GLOBALG.A.P. requires the corresponding certification body (CB) and certificate holder to refute the claim. This can be achieved by verifying and providing evidence of compliance with the GLOBALG.A.P. standard. CBs investigate the complaints through document reviews and, if needed, unannounced assessments. They must then report all findings and action taken to GLOBALG.A.P. by a defined deadline.
In some cases, the Certification Integrity team will perform targeted Integrity Assessments for onsite investigation and follow up. Complaints information is therefore shared with the Certification Integrity team to facilitate the selection and scheduling of Integrity Assessments.
Breakdown of complaint categories in 2020
Hover over the bars to see the breakdown.
Complaints per General Regulations category in 2020
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residues monitoring system
Complaint investigation process
GLOBALG.A.P. has a dedicated team of experts to investigate complaints relating to Maximum Residue Limits (MRL). The MRL complaint process is as follows:
- A complaint is received by GLOBALG.A.P.
- The complaint information is checked (producer status, analysis report, traceability information, etc.), recorded in the complaint management system, and then sent to the relevant CB.
- The CB investigates the complaint and sends their conclusions to the GLOBALG.A.P. technical team:
- Phase one: The CB performs a document check and sends GLOBALG.A.P. information on the last producer assessment.
- Phase two: In most cases, an unannounced audit is carried out at the producer premises and the situation is investigated on site.
- Additional GLOBALG.A.P. investigation:
- Sampling by Food Experts: In some cases, GLOBALG.A.P. commissions an independent expert to check traceability and take a sample at origin. The sample is tested in an accredited laboratory.
- Chain of Custody: In some cases, a GLOBALG.A.P. expert contacts several agents in the supply chain to verify or complement the investigation carried out by the CB with the producer.
- GLOBALG.A.P. experts cross-check and challenge information received. In most cases, the CB will provide the clarification which is needed. If not, additional investigations are carried out.
- The GLOBALG.A.P. Complaints Management team summarizes the investigation in a 1–2 page report, which is sent to the complainant.
- If the GLOBALG.A.P. technical review identifies a potential risk, the information is passed on to the Certification Integrity team.
Number of cases investigated per country in 2020
Hover over the highlighted map sections to see the number of investigated cases in each country.
In 2020, the most MRL complaints were recorded in Spain (35 cases), Peru (34 cases) and Germany (26 cases).
Status of complaints received
At the end of 2020, there were 21 open investigations to be resolved in 2021.
While an investigation typically lasts for two months, it can take much longer. During 2020, the main contributing factors for extending the duration of an investigation included:
- Chain of Custody problems: The information provided with the complaint does not relate to the producer. In most cases, the product has been packed by another legal entity or re-packed at destination. The supply chain must then be investigated to find the source of complaint.
- The CB has no auditors in the country where the producer is located, and therefore long-distance travel arrangements are needed.
- The CB’s auditors face scheduling or logistical issues which mean an unannounced inspection takes several weeks to organize.
- The CB detects non-compliances during the unannounced investigation and – in accordance with the General Regulations – the producer has 28 days to submit corrective actions. The CB has another 28 days to take a certification decision.
- GLOBALG.A.P. challenges the investigation outcome and the CB needs to re-orient the investigation and continue with a new investigation.
Number of cases investigated per crop
Hover over the bars to see the number of investigated cases for each crop type.
During 2020, the most frequent sources of complaint were leaf crops (17 cases), citrus (16 cases), and aromatics (15 cases).
*Leaf crops, also known as leafy or salad greens, are plant leaves eaten as a vegetable (lettuce, cabbage, herbs, etc.). The highest-risk types are those with an open growth aspect (e.g., spinach), or those with the edible parts of the leafy green plant grown close to the ground.
**The exotics category includes a wide variety of products.
MRL incidences in 2020 according to category
Most of the MRL exceedance cases detected in 2020 were not due to the agricultural practices of certified producers, proving that the system is improving year-on-year. Instead, investigated MRL incidences were found to be largely due to adjacent producers, traders, and re-packers.
Results of MRL investigations in 2020
Hover over the chart sections to see the breakdown of incidences.
Click the category headings below for an explanation.
Normally drift from an adjacent field. In most cases, the adjacent field is not GLOBALG.A.P. certified.
The producer is QS-GAP certified. QS undertakes the investigation by taking a second sample and if the result is acceptable, the investigation is closed.
This category includes issues such as GGN misuse by a non CoC-certified re-packer or supply chain member.
The CB investigation could not identify the cause of the reported exceedance, or a plausible reason was found but could not be demonstrated to be the origin of the exceedance. In these cases, the producer is requested to take appropriate measures in order to rectify the detected weak points. Some cases in which no reason was found may be forwarded to the Certification Integrity team following review by the MRL technical experts.
Information must be traceable along the supply chain to investigate an MRL case and match the analyzed product to a specific batch from the producer. In some cases, this is not possible, and therefore reliable traceability information cannot be obtained.
The most frequent issue in this category is the low degradation-rate of pesticides.
Problems linked to PO and/or PP were identified as the source of the incidence. This is only applicable to cases where the producer is registered for PP/PO. Common examples are mixing non-certified products with certified products, or an ineffective segregation system which could have led to mixing of the products.
The most common issue included in this category is using pesticides with very low MRL in the EU and not increasing, not increasing enough, or failing to comply with the label pre-harvest interval (PHI). Misuse also covers the application of non-authorized active ingredients and other similar causes.
Cases that were not investigated due to lack of evidence proving that the product came from the certified producer.
All the cases included in this category are due to phosphonic acid residues coming from an application other than fosetyl-Al.
Common issues include labeling with incorrect GGNs, producers labeling non-certified products with a GGN, and non-authorized use of the GGN.
The affected product was not sold as certified by the producer and is therefore not a matter for a GLOBALG.A.P. investigation. Even if the producer is under certification another product type, the product in question must be clearly indicated as being from a GLOBALG.A.P. certified production process on the invoicing/trading documents to qualify for investigation.
Includes a range of scenarios, as well as business related issues outside of GLOBALG.A.P.’s jurisdiction. Examples from previous years include issues with pesticide application machinery or cases where no information about the root cause of the problem can be provided or identified.