Integrity Report 2021
An efficient and fair response system
Complaint investigation procedure
Complaints received by the GLOBALG.A.P. Secretariat are recorded, analyzed, and investigated by a dedicated complaint management officer. Reports regarding a breach of standard requirements by GLOBALG.A.P. system users – including breaches related to maximum residue limits (MRLs) – 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 a potential non-compliance with the standard requirements is traced to a producer, producer group, or company with certified production processes, the GLOBALG.A.P. Secretariat requires the corresponding certification body (CB) and certificate holder to refute the claim. This can be done by verifying and providing evidence of compliance with the GLOBALG.A.P. standard.
CBs investigate the complaints through document reviews and, if needed, unannounced integrity assessments. They must then, within a defined time period, report to the GLOBALG.A.P. Secretariat all findings and action taken.
Complaint information is shared with the Certification Integrity team to facilitate the selection and scheduling of integrity assessments. This may result in targeted integrity assessments for on-site investigation and follow-up.
Breakdown of complaint categories in 2021
Hover over the sections to see the percentage share of the total for each category.
Related to issues that are either not covered by the GLOBALG.A.P. standards or need certain clarifications in the context of the GLOBALG.A.P. standards. For example: The standard does not cover a specific requirement, and the GLOBALG.A.P. Secretariat should improve the rules or criteria to include it.
Related to the daily operations and tasks of the GLOBALG.A.P. departments. For example: A stakeholder was not invited to a specific event, a complaint was filed against a specific GLOBALG.A.P. team member, or a CB has not received official news communications/email newsletters.
Related to GLOBALG.A.P. logo/trademark/GGN uses which are not compliant with the corresponding requirements of the GLOBALG.A.P. general regulations. For example: A producer without certification is making a certification claim on their website (brand misuse); a producer with certified production processes is using the GLOBALG.A.P. logo on the consumer packaging label of the product (logo misuse); or a producer with noncertified production processes is using the GGN of another producer with certified production processes (GGN misuse).
Related to claims that do not fall under GLOBALG.A.P.’s responsibility. For example: A participant in a CB’s GLOBALG.A.P. training seminar received a certificate with their name written incorrectly and asked the GLOBALG.A.P. Secretariat to reissue it with the correct name.
Related to the CB’s integrity and impartiality of its certification services. For example: The CB or its auditors are providing consultancy services to their own customers or performing an audit without CB approval for the relevant standard/scope/sub-scope/add-on.
Related to certificates that were issued without following proper procedure according to the GLOBALG.A.P. general regulations. For example: Certificates were issued by a non-approved CB or certificates were issued without an audit.
Related to deviations from the requirements of the GLOBALG.A.P. general regulations. For example: GLOBALG.A.P. audits were conducted at the wrong time (outside the defined audit window), double registrations were made, or certification decisions were delayed.
Related to the GGN label or the GGN label portal. For example: The requirements for use of the GGN label are not fulfilled.
Related to the daily operation and functionality of the GLOBALG.A.P. database. For example: A user complains after experiencing reduced performance of the GLOBALG.A.P. database.
Related to the GLOBALG.A.P. Integrity Program. For example: A CB complains about a specific key performance indicator (KPI) rating.
Related to complaints in which there is not enough information to process and start an investigation, or in which the communication is a request/inquiry rather than a complaint. For example: A complaint without valid information (producer name, GGN, etc.) was received.
Related to the Registered Trainer program that conducts training on GLOBALG.A.P. standards (the successor to the GLOBALG.A.P. Farm Assurer program which ran from 2011 to 2021). For example: A Registered Trainer/Farm Assurer is claiming to be a GLOBALG.A.P. representative.
Breakdown of complaints by normative document
Hover over the sections to see the percentage share of the total.
Number of cases investigated per country in 2021
Hover over the map sections to see the number of cases investigated in each country.
residues monitoring system
Complaint investigation process
GLOBALG.A.P. has a dedicated team of experts to investigate complaints relating to MRLs. The MRL exceedance complaint process is as follows:
- GLOBALG.A.P. receives a complaint.
- 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:
- 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 audit/inspection.
- Phase two: In most cases, an unannounced audit/inspection is carried out at the producer’s 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.
- GLOBALG.A.P. Chain of Custody (CoC): 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 the 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. Complaint Management team summarizes the investigation in a 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.
Maximum Residue Limits (MRL) complaints
Number of MRL exceedance complaints investigated per country in 2021
Hover over the bars to see the number of investigated cases per country.
In 2021, the most common countries of origin for MRL complaints were Italy (21 cases), Spain (12 cases), and China (9 cases).
*“Country not defined” refers to a received complaint that could not be investigated due to lack of sufficient traceability information. Therefore, the country of origin for this MRL exceedance complaint could not be defined and the complaint was rejected.
Number of MRL exceedance cases investigated per type of crop in 2021
Hover over the bars to see the number of investigated cases for each type of crop.
During 2021, the most frequent sources of MRL exceedance complaints were exotics (18 cases), citrus (13), leaf crops (12), and salads (12).
Compared to the previous year, complaints concerning exotics have increased from 10 to 18, representing the category with the highest number of complaints in 2021. Complaints concerning leaf crops, aromatics, table grapes, or berries have reduced in number significantly.
Of all MRL exceedance complaints received in 2021, the highest number was for leaf crops from Italy (7 cases), exotics from Colombia (6 cases), exotics from Brazil (5 cases), and citrus from China (4 cases).
Results of MRL investigations per category in 2021
Hover over the chart sections to see the incidence breakdown.
Click the headings below for an explanation of the result categories.
Drift from an adjacent field which, in most cases, is not covered by GLOBALG.A.P. certification.
The producer is QS-GAP certified. QS conducts the investigation by taking a second sample. If the result is acceptable, the investigation is closed.
This category includes issues such as GGN misuse by packer or supply chain member without CoC certified processes.
The most frequent issue in this category is the low degradation rate of plant protection products.
Problems linked to PO and/or PP were identified as the source of the incident. This is only applicable to cases where the producer is registered for PP/PO. A common example is an ineffective segregation system resulting in the mixing of products from noncertified production processes with products from certified production processes.
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 exceedance 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 common issue included in this category is the use of pesticides with very low MRLs in the EU and not increasing, not sufficiently increasing, or failing to comply with the preharvest interval as indicated on the label. Misuse also covers the application of nonauthorized active ingredients and other similar causes.
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 products from noncertified production processes with a GGN, and other nonauthorized uses of the GGN.
Cases that were not investigated due to lack of evidence proving that the product came from a producer with GLOBALG.A.P. certified production processes.
Includes a range of scenarios as well as business-related issues outside of GLOBALG.A.P.’s jurisdiction, such as issues with plant protection product application machinery.
The affected product was not sold as originating from a GLOBALG.A.P. certified production processes and is therefore not a matter for a GLOBALG.A.P. investigation. Even if the producer is under certification for another product type, in order to qualify for investigation, the product in question must be clearly indicated on the invoice/trading document as originating from a GLOBALG.A.P. certified production process.
MRL investigation outcomes in 2021
In 2021, the number of MRL exceedance complaints was similar to 2018 (89 complaints received), but lower than 2020, 2019, 2017, and 2016 (128, 107, 108, and 134 complaints received, respectively).
Most of the MRL exceedance cases detected in 2021 were not due to the agricultural practices of producers with certified production processes, proving that the system is improving each year. Instead, investigated MRL incidents were found to be largely due to adjacent producers, traders, and repackers.
Producers and CBs are aware of the consequences of drift contamination from adjacent producers and are working to minimize it. This was also stated in the integrity reports for the last two years, and effectiveness has been proven by a decrease of 46% over three years from 39 cases in 2019 to 30 cases in 2020 and further to 21 cases in 2021.
“No reason found” was the conclusion for 15 cases in 2021 because the investigation showed no clear origin of the exceedance. In all of these cases, corrective actions were proposed and effectiveness will be verified during the next certification cycles.
“Lack of traceability” was the conclusion for 13 cases in 2021. Concerning traders and repackers, there is little that producers can do. The most important step here is encouraging retailers to ask for GLOBALG.A.P. Chain of Custody certification along the supply chain.
Pesticide misuse is mostly due to the use of pesticides with very low MRLs in the EU and producers’ not increasing (or not sufficiently increasing) the preharvest interval or not complying with the preharvest interval as given on the label.
Status of open investigations
At the end of 2021, there were 21 open investigations to be resolved in 2022.
While an investigation typically lasts for two months, it can take much longer. During 2021, the main contributing factors for extending the duration of an investigation included:
- Chain of custody problems where 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 repacked at destination. The supply chain must then be investigated to find the source of the problem.
- The CB has no auditors/inspectors in the country where the producer is located, and therefore travel arrangements are needed. This was complicated further by the wide-ranging and diverse restrictions enacted by national governments during the pandemic.
- The CB’s auditors/inspectors face scheduling or logistical issues which mean an unannounced audit/inspection takes several weeks to organize.
- The CB detects non-compliances during the unannounced audit/inspection and – in accordance with the GLOBALG.A.P. 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 reorient the investigation and continue with a new investigation.