Part 3: Geographical Indication control approaches

Part 3: Geographical Indication control approaches

A primary consideration when developing a GI control system is who will set up and manage the controls. Should it be a public authority, the producers or the producer group as a single entity. Consideration must also be given to the best control system to match the needs and capacity of stakeholders. Both private and public implemented controls can be considered.

Levels of controls

There are three levels of controls to consider when developing a GI control system:

1. A self-control or auto control system established and managed by producers themselves and operators of the value chain.
2. An internal control system which is not compulsory. Such as system will depend on the provisions established in the relevant legal framework. This internal control can be implemented by GI associations or a group of GI producers or outsourced under the responsibility of the GI producers' group.
3. An external independent control system which will involve checking the control systems being utilized by users of the GI logo to ensure compliance with the control system for the product. This level of control is mainly provided by a certification body or sometimes by public organizations such as a bureau of standards if appropriately accredited or legally competent.

External controls can be carried out by different types of actors such as public bodies; private organisations, technical teams/commissions. All external control entities must have the specific competency to undertake conformity assessment for GI control schemes as well as having specialised expertise related to the product.

Choosing a control body

When the legal regulation foresees the intervention of certification body, such a body must be accredited by an internationally recognized body like ISO 17,065 and selected by the producer group during the drafting of the specifications. The independence of the control body is important for monitoring and enforcing the control system and this will provide a layer of transparency to the GI management system.

The control body would provide an accreditation certificate indicating whether a producer is in conformity with the GI plan for a specific product and therefore qualified to continue to use the GI label.

Contents of the control plan

The control plan will typically comprise the following elements:

•   Reference to the product specification
•   Definition of the scope of application of the control plan
•   Explanation of the organisation of controls in terms of the staff involved in the certification process and the process to enable the procedures to be certified
•   Definition of the modalities of control. For each checkpoint, you need to know what type of control you will have to implement: auto controls and / or internal controls and / or external controls
•   Explanation of the sanctions/penalties for failure to comply
•   Information to provide to Control/Certification bodies:
  • - Information about the contact, the address and the existence of other certifications.
  • - Information about the production process - plant production, animal production, processing activities, storage details, placing product on the market. This information will depend on the content of the specification.

For each producer, a first certification audit must be undertaken before they can be authorised to use the GI.

Example of records for plant production

There must be a register, which is always made available to the control authorities or bodies. Pertinent information which must be kept in the register include, as examples:

•   Fertilizer use: date of application, type and amount of fertilizer, parcels of land where fertilizer was applied
•   Plant protection records: reason and date of treatment, type of product, method of treatment
•   Purchase of farm inputs: we need the date, the type, the amount of the purchased product and sometimes also the labelling
•   Harvest data: we need the date, the type and amount of organic or conversion, crop production

Organoleptic tests

Organoleptic tests are not compulsory and are only implemented if it is relevant to a specific product and if there are some special product conditions defined within the specifications. If such a test is required then there is need to identify and constitute a competent testing panel, the details (for example naming the panellist, providing a checklist) of which would have been provided in the code of practice for the GI product.

GI controls checkpoints

The following provides information on checkpoints which may be applicable when an external control body is used. This is not an exhaustive list and will be dependent on the product.

Checkpoints for the general and documentary organization will include:

•  

  Respect and adherence to the general conditions of certification - commitment of the stakeholder’s, management of new applications.

  The method of controls for this checkpoint includes: assessment of the statutes and internal regulation of the GI producer group, its organisation and management rules, agreement on the certification by the certification body, accession agreement

•  

  Documents managed by the group of producers.

  External control methods will include - monitoring and follow-up of official documents, quality control documents; procedural documents produced by certification body; updated list of authorised operators or stakeholders that will use the Geographical Indication.

Training and the information on training which producers have received. Checkpoints will include:

•   The certification body will control the dissemination of quality documents by the association to the producers.
•   Methods of control – verifying the dissemination of informative documents, registration documents, traceability documents, and sometimes also trainings; checking the qualification of the staff that is used within the GI association to implement internal controls. In this case, the external control will check the competency of internal controllers.

Understanding the elements of a control plan

A control plan is built around three main parts:

1. The criteria related to product specification and the key point to master
2. The monitoring plan - which action will be implemented in order to check the point to master or to check if the criteria comply with the product specification, who is responsible for the control, how many times a year, and the corrective action required if there is non-compliance
3. Documentation of the results of assessments and required action etc.

GI Certification

Issuing a GI certificate of compliance is not compulsory and will depend on the relevant existing legal framework. Certificates are issued by the control/certification body for compliant products and producers based on the test and audit results.

Conclusions

•   To implement an effective GI control system, there must be a clear understanding of the product and market dynamics
•   The producer group must lead the development and implementation of the control system
•   The control/certification body does not lead the implementation of the GI controls
•   Building a strong relationship between the producers and the certification body is critical
•   Producers and the producer group must be vigilant with regards to ensuring all authorised users of the GI designation are compliant with the GI specifications and control plan. In so doing they can maintain a sustainable GI system for their product

Learning exercises

Question 1: CIs a certification body mandatory in relation to the GI control system?

Question 2: Is the GI group entitled to provide internal controls?

Question 3: In the overall GI control plan can I include some controls which will be relevant in the marketplace?

Question 4: Can I use other certification schemes as part of my GI control system?

Question 5: In the case of several certification schemes, can the various bodies pool resources for their audits?

Question 6: During the audit undertaken by the control/certification body some documentation which can be used as evidence of conformity is missing. Is it a condition of refusal of the GI certification?