GMO Free Turkish Cotton

Accredıtatıon Requırements and Procedures for Certıfıcatıon Bodıes

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GMO FREE TURKISH COTTON
Accreditation Requirements and Procedures for
Certification Bodies
01.01.2020
Version.1
Prepared by TRADEMARK OWNERS İzmir Commodity Exchange, National Cotton Council, Unions of
Exporters of Textiles and Raw Materials of İstanbul.
Prepared by
İzmir Commodity Exchange, National Cotton Council, Union of Exporters of
Textiles and Raw Materials of İstanbul
Address: Gazi Bulvarı No:2 Konak- İzmir
Phone / Facsimile 0232 481 1165
E-mail info@gmofreeturkishcotton.org, info@itb.org.tr; info@upk.org.tr
Website www.gmofreeturkishcotton.org

CONTENTS
1. Object of This Guide
2. Principles
3 Scope
4. Accreditation and Surveillance Procedure
4.1. Prerequisites for Certification Bodies
4.2. Application Procedure
4.3. Inspection and Assessment Requirements for Accreditation Bodies
4.4. Approval Decision
4.5. Publication of and Requirements for Accredited Certification Bodies
5. Requirements for Certification Bodies
5.1. General Terms
5.1.1. Responsibilities
5.1.1.1. Legal Structure
5.1.1.2. Certification Contract
5.1.1.3. Responsibility for Certification Decisions
5.1.1.4. Acceptance of Decision of Other Certification Bodies
5.1.2. Personnel
5.1.2.1. General
5.1.2.2. Qualification Criteria and Certification
5.1.2.3. Provision and Maintenance of Competence
5.1.2.4. Appointment of Personnel
5.1.2.5. Appointment of Committees
5.1.2.6. Use of Subcontractors (Outsourcing)
5.1.3. Impartiality and Objectivity
5.1.3.1. Organisational Structure and Stakeholder Relationship
5.1.3.2. Impartiality Management
5.1.3.3 Segregation of Responsibilities
5.1.3.4. Accessibility
5.1.4. Access to Information
5.1.4.1. Publicly Available Information
5.1.4.2. Confidentiality
5.1.4.3. Certification Reference and Use of Certification Logo (signature)
5.1.5. Quality Management System
5.1.5.1. General
5.1.5.2. Management System Guide
5.1.5.3 Document Control
5.1.5.4. Keeping and Management of Records
5.1.5.5. Internal Auditing and Management’s Review
5.1.5.6. Objections and Complaints
5.2. Requirements for GMO-FREE TURKISH COTTON Certification
5.2.1. Application Procedures
5.2.1.1. Information for Entrepreneurs
5.2.1.2. Application Form and Obligations of Entrepreneurs
5.2.2. Assessment
5.2.2.1. Scope
5.2.2.2. Assessment of Application and Preparation for Inspection
5.2.2.3. Inspection Protocol
5.2.2.4 Special Requirements for High-Risk Situations
5.2.2.5. Reporting
5.2.3. Certification Decision
5.2.3.1 Segregation of Responsibilities
5.2.3.2. Basis for Decision
5.2.3.3. Certification
5.2.3.4. Management of Nonconformities
5.2.3.5. Exceptions to Certification Requirements
5.2.3.6. Issuance of Certification Documents
5.2.4. Extension and Renewal of Certificate
5.2.4.1. Continuity of Assessment
5.2.4.2. Inspection Frequency
5.2.4.3. Notification of Changes Made by Entrepreneur
5.2.4.4. Modifications in Certification Requirements
5.3. Assessment of Textile Auxiliary Materials (chemical inputs)
5.3.1 Application Procedures
5.3.1.1 Information for Entrepreneurs
5.4. Special Requirements for GMO-Free Turkish Cotton Accredited Certification
Bodies
5.4.1. Annual Fee
5.4.2. Collection of License Fee
5.4.3. Competition
5.4.4. Publicly Available Database, Activity Reports
5.4.5. Cooperation with Other Accredited Certification Bodies
6. Abbreviations
7. Definitions

1. Object of This Guide
This document stipulates the receiving and maintenance of approval as well as accreditation and
Surveillance procedures to allow the Certification Bodies to be able to carry out certification
pursuant to the GMO-Free Turkish Cotton Standard and to implement the relevant quality control
system.
2. Principles
Organisations providing independent third party inspection and certification services may file an
accreditation application with the TRADEMARK HOLDER to be a GMO-Free Turkish Cotton Accredited
Certification Body. Such organisations will be hereinafter referred to as “Certification Bodies”.
For this approval process and for the continuous monitoring of Certification Bodies,
• The TRADEMARK HOLDER collaborates with the accreditation bodies providing such service
in order to implement the GMO-Free Turkish Cotton accreditation and Surveillance
procedure;
• The TRADEMARK HOLDER signs an agreement with an “ACCREDITATION BODY” that has
signed an MLA with an IAF member and EA in the implementation of the accreditation
procedures of this standard which belogs to Turkey;
• The TRADEMARK HOLDER agrees that the accreditation procedures will be carried out by the
actual accreditation authority;
• Such accreditation body must be nationally or internationally recognised (such as an IAF
member) and comply with the ISO/IEC Guide 17011: 2004 “General Requirements for
Accreditation Bodies Assessing and Accrediting Conformity Assessment Bodies” procedures;
• It must follow the designated procedures in order to provide accreditation for the GMO-Free
Turkish Cotton scope;
• This guide is based on Certification bodies ISO/IEC 17065:2012 “Conformity Assessment –
Requirements for bodies certifying products, processes and services”.
3. Scope
Procedures and requirements as set forth in this guide are valid for those Certification Bodies that at
the stage of a new application and that are presently accredited for GMO-Free Turkish Cotton. As lıng
as any other rule is set, it is required to comply with the requirements in the current version of this
guide for the Certification Bodies that will file an accreditation application.
4. Accreditation and Surveillance Procedure
4.1. Prerequisites for Certification Bodies
Those Certification Bodies that have filed an application for accreditation as a GMO Free Turkish
Cotton Accredited Certification Body must be already accredited in the international organic food
and textile industries basing upon the ISO/IEC 17065:2012 “Conformity assessment – Requirements
for the bodies certifying products, processes and services”.
4.2. Application Procedure:
A Certification Body may file an application for one of both of the following scopes:
Scope 1-Fibre and Fibre Products Certification: It covers the following issues:
• Assessment of mechanical textile and manufacturing operations
• Assessment of wet processing, finishing operations
• Assessment of business operations
• Assessment of colourants and textile auxiliary chemicals.
Note 1: Textile colorants and auxiliary chemicals approved for the international organic textile
standards are allowed to use. (ZDHC and / or GOTS Approved Materials List).
Note 2: Any approval certificates may not be issued to any textile colorants and auxiliary chemicals as
per the GMO-Free Turkish Cotton Standard.
Scope 2-Cotton Seed and By Products: Cottonseed oil, cottonseed meal, cottonseed, linter
1. Accreditation applications for those Certification Bodies wishing to file an application file their
application made by using the application form available at the link via e-mail
(info@www.gmofreeturkishcotton.org )

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2. Application will only be assessed once the following information/documentation has been sent:
a) Legal name, status, address and applicant’s legal representative;
b) List of the applicant’s all offices and representation offices;
c) Scope(s) for which the applicant requests GMO-Free Turkish Cotton accreditation;
d) A copy of each of the applicant’s accreditation certificates and a list of the ISO 17065 accreditation
scopes;
e) Application filed with the accreditation body following the acceptance of the application by the
TRADEMARK HOLDER;
f) Statement of the applying Certification Body as to the fact that it will comply with the GMO-Free
Turkish Cotton Standard and all requirements of this guide and that it will sign the TRADEMARK
HOLDER’s ‘Certification Body Contract’ if its application is approved;
g) Evidence of the relevant professional qualification and experience of each of the identified
personnel including their CVs, a list of the audits they have carried out and training they have
received; a list of the audits and trainings on textiles for the textile scope and on agriculture and food
for the scope concerning food.
3. Applications should be filed accompanied by a non-refundable transaction charge + VAT.
Transaction Charge should be deposited in the bank account to be designated by the TRADEMARK
HOLDER.
4. Upon the acceptance of the application by the TRADEMARK HOLDER, the Certification Body should
file its application regarding the scope with the ACCREDITATION BODY. The applicants should deposit
the non-refundable + VAT (“Application Fee”) in the bank account to be designated by the
TRADEMARK HOLDER. Such fee should be paid upon the conclusion of an accreditation contract by
and between the ACCREDITATION BODY and the Certification Body.
4.3. Inspection and Assessment Requirements for Accreditation Bodies
Accreditation Bodies must comply with the ISO/IEC El Guide 17011: 2017 “Conformity assessment —
general requirements for accreditation bodies accrediting bodies assessing conformity” procedures
and agree to follow the GMO-FreeTurkish Cotton approval and Surveillance procedure as specified in
this guide.
TRADEMARK HOLDER obliges the designated accreditation body to include the following points of
inspection and surveillance into the relevant accreditation and surveillance procedure as a minimum:
a) Accreditation inspection at the head office of the applying Accreditation Body.
b) A witness inspection carried out at an enterprise considered to be critical out of those enterprises
which use GMO Free Turkish Cotton fibre for the applying Certification Body. In case it holds
accreditation within the scope of Cotton Seed and By-Products, a witness inspection carried out at an
enterprise considered to be critical out of the enterprises processing relevant products.
c) Implementation of at last one biennial accreditation inspection at the offices of the Accredited
GMO-Free Turkish Cotton Certification Bodies implementing GMO-Free Turkisg Cotton Certifiction.
Implementation of at least one witness or examination (on-site control of field inspection) inspection
every seond year following the accreditation in order to monitor conformity.
d) Control of at least 5 entrepreneur files or 1,5% of the entrepreneur files for which contracts have
been concluded by the Certification Body (whichever is higher) during each accreditation inspection.
e) Control of the procedures carried out by the Certifiction Body regarding the assessment of the
textile chemicals as contained in the scope of wet textile operations, personnel and assessments in
each accreditation period.
f) Provision of the TRADEMARK HOLDER with information prior to each accreditation inspection by
the ACCREDITATION BODY.
g) Notification of the TRADEMARK HOLDER of a staff member of the ACCREDITATION BODY who is
responsible for the environmental and social inspections as per the accreditation procedures.
h) Provision of the TRADEMARK HOLDER of each accreditation decision made by the ACCREDITATION
BODY.
Note: TRADEMARK HOLDER reserves its right to inspect each and every record of the Certification
Body and to attend the Accreditation Body inspections.
4.4. Approval Decision
ACCREDITATION BODY decides whether or not the Certification Body will be accredited within the
scope(s) for which application is filed on the basis of this procedure and the requirements hereof
(see 4.2.2.c) (‘GMO-Free Turkish Cotton Accreditation’).
The accreditation body may decide to accredit only one or more of the scopes for which application
is filed or may reject to accredit the scopes for which application is filed.
Conclusion of the accreditation is a prerequisite so that the contact may be signed by and between
the TRADEMARK HOLDER and the Certification Body.
Once the Certification Body contract has been signed, the Certification Body is entitled to act as an
Accredited Body and to carry out the relevant GMO-Free Turkish Cotton Certification. Accredited
Certification Bodies must be accredited for at least one standard which conforms to the ISO/IEC
17065 and ‘GMO-Free Turkish Cotton’ accreditation at all times. The TRADEMARK HOLDER reserves
its right to suspend or terminate the contract, to limit the accredited scope as mentioned in the
‘Certification Body Contract’ and to provide the accreditation body with information for the
investigation of any potential problems.
4.5. Publication of and Requirements for Accredited Certification Bodies
GMO-Free Turkish Cotton Certification Bodies and accredited scope(s) shall be published in the
GMO-Free Turkish Cotton website. Besides, in case any provision of this guide is violated and/or is
enforceable , they will also be published in the GMO-Free Turkish Cotton website in order to ensure
the accreditation body to be notified by the TRADEMARK HOLDER.
² Witness and review audits are specific audit tools of accreditation bodies. In the witness audit, the accreditation body
accompanies the auditor/audit team during the field audit and evaluates the performance. In the inspection audit, the
accreditation body audits the audited/certified economic operator together with the previous audit report, without an auditor or
audit team whose performance will be measured, or by being present only to monitor it.
5. Requirements for Certification Bodies
5.1. General Requirements
5.1.1. Responsibilities
5.1.1.1. Legal Structure
Structure of the certification body must give confidence in certification procedures. Certification
Body must particularly
a) confirm that it is a legal organisation;
b) document its rights and obligations regarding certification; and
c) describe the management (organisation, group, individual) retaining the responsibility for the
operation of the certification body including accounting.
5.1.1.2. Certification Contract
The Certification Body must provide the certification service pursuant to a legally valid contract
signed by entrepreneurs. In the contract,
a) Provides a description of the rights and duties of the entrepreneurs who produce using
certified inputs as well as the other requirements of the GMO-Free Turkish Cotton Standard,
Labelling and Licensing Guide and those of the GMO-Free Turkish Cotton Certification programmes
determined or to be determined by the TRADEMARK HOLDER as a minimum;
b) Provides the right to have access to the Certification Body and the Accreditation Body and all
inspected units including those units where any products not covered by the GMO-Free Turkish
Cotton are processed, stored or managed (if any) as well as to all relevant documents and records
including the financial records;
c) In case the entrepreneur advertently or inadvertently causes any nonconformity on any matter
related to the organic production rules, then he agrees to any sanctions as required by the
production rules in question. Upon the suspension, revocation or expiration of the certification, the
entrepreneur ceases to use all advertising materials making any reference to the certification and
takes any necessary action in the certification plan (i.e., he returns his certification documents) and
take any other necessary measures;
d) Keeps a record of all complaints filed about his compliance with the certification requirements
and makes such records available for the Certification Body and the TRADEMARK HOLDER upon
request; and
-takes any proper measures which affect the conformity of such complaints and any deficiencies in
the products to the certification requirements;
-enters any preventive actions in the records;
e) In case any modification is made which may affect the conformity to the certification
requirements, then the entrepreneur notifies the Certification Body of such modification without delay;
f) allows the Certification Body inspecting him to verify the certification procedures and exchange
information with the other Accredited Certification Bodies, TRADEMARK HOLDER, Accreditation Body
and any other legal institutions and organisations which may be relevant as part of the ongoing
assessment;
) declares that he will not simultaneously work with any other Certification Body within the scopes
belonging to the GMO-Free Turkish Cotton.[2]
3 Any enterprises that process the products as a subcontractor in the supply chain need not be
further certified individually pursuant to the GMO-FREE TURKISH COTTON standard (in the area of
intermediate operations or manufacturing). Enterprises of this kind may be engaged as
subcontractors by entrepreneurs and similarly inspected by different Certification Bodies.
Subcontractors may be contained in the conformity certificates of the principal entrepreneur
5.1.1.3. Responsibility for Certification Decisions
The Certification Body is the decision maker for issuing, sustaining, extending and revoking the
certificate
5.1.1.4. Acceptance of Decision of Other Certification Bodies
The Certification Body will accept any documents issued in accordance with the GMO-Free Turkish
Cotton by any other Certification Bodies when it must use such documents in any certification
decisions which it will make.
Further, the Certification Body will accept any documents issued in accordance with the GMO-Free
Turkish Cotton provisions by other Certification Bodies as well as any analysis reports issued by
analysis laboratories (paragraph 2.1, 4.2).
5.1.2. Personnel
5.1.2.1. General
a) The Certification Body will employ an adequate number of employees who are competent enough
to carry out the certification activities and system.
b) The Certification Body will ensure that the staff members whom it has designated for the
certification procedures will have adequate knowledge, training and experience regarding the
activities of the enterprises as covered by certification.
c) The Certification Body will keep current records for the individuals it employs. The records will
include the following:
– full name and address;
– assignments;
– education and job competence status;
– experience and training (current list of the inspections carried out and trainings received);
– competence assessment;
– periodical performance assessment (particularly for those inspectors who have been recently
appointed within this scope, accompaniment to at least 4 inspections under the supervision of an
experienced inspector);
– powers within the Certification Body;
– last updating dates of the records.
5.1.2.2. Qualification Criteria and Certification
a) The Certification Body will describe minimum competence criteria for its employees who are
expected to be authorised in the GMO-Free Turkish Cotton standard practices.
The criterion will describe the minimum training, technical information and job experience related to
the scope of the issued certificate.
b) The Certification Body will officially authorise its employees who are assigned to carry out the
certification procedures.
c) In order to make a GMO-Free Turkish Cotton certification decision at the Certification Body, at last
one employee so assigned must have the following competences:
1-For inspections related to textile products:
· Textile engineer
· 3 years’ practical field experience in the textile area
· Ongoing position as inspector/certifier in any similar international programmes
· Evidence (SSO) as to his experience on the Quality Management Systems and his assignment in
the certification programmes carried out at textile enterprises.
Personnel of the certification body (inspector and/or certifier) must have a good command of the
regulations related to the national textile industry (environmental and social). Any staff members
who have been appointed for the inspection of the GMO-Free Turkish Cotton technical, social and
environmental criteria at textile enterprises (inspector / certifier) must have been trained on one of
the internationally recognised technical, social and environmental standards and/or have
competence on inspecting/ certifying on one of the similar sustainable standards.[3]
2-On Cottonseed and by-products thereof
The Certification Bodies accredited for the Cottonseed and By-Products scope will assign actually
working inspectors and certifiers approved by the Ministry, who have been qualified as Organic
Agricultural Controllers/certifiers.
· Agricultural Engineering or Food Engineering diploma;
· 3 years’ experience in at least one of the international organic agriculture regulations;
· Beside experience, ongoing position as an active organic agriculture inspector/ certifier at an
inspection body; and/or
· 3 years’ field experience on production and experience on Quality Management Systems at
food enterprises and inspection/certification power granted by the Ministry;
· Evidence as to the fact that he has been given assignments in the certification programmes
being implemented at the enterprise for a period of 2 years (SSO and advisory works implemented
for preparation for organic certification) and inspection/certification power granted by the Ministry.
The Certification Body must keep such current documents as Job Descriptions, appointment letters,
trainings provided, etc. in which it identifies the responsibilities of the employee whom it has
assigned.
4 The TRADEMARK HOLDER plans the organisation of the trainings on any subjects needed for the inspectors and certification personnel.
The subjects and other information regarding the planned trainings will be notified to the Certification Bodies and they are important for
the continuation of the accreditation of the Certification Body for the relevant standard. Therefore, it is mandatory to attend any training
studies to be organised.
5.1.2.3. Provision and Maintenance of Competence
The Certification Body will make sure that the staff members appointed by it (e.g.,
Inspector/Certifier/Committee and its Members and other relevant support personnel) have current
technical information in their own respective areas so that the assessment and certification
processes carried out by them may be effectively and orderly carried out.
In particular, the Certification Body
a) must carry out the annual competence assessment of the administrative and support personnel
involved in the implementation of the standard and shadow inspections at predetermined intervals
and assess the competence of the inspectors in order to identify the training needs.
b) will make sure that any new employees have competence. New inspectors must receive
competence training and gain experience by attending field inspections under the supervision of the
qualified personnel before they go out for field inspections for the GMO Free Turkish Cotton
Certification. Depending on the number of entrepreneurs and the geographical structure, the
Certification Body must cause such personnel to attend at least four inspections. It must have
assessed the accreditation scopes to which appointment will be made in the general trainings
implemented and the trainings attended.
Note: The Certification Bodies may refer to the ISO/IEC 17021 Annex D for the guide to the
qualification and conduct of the good inspectors while assessing the inspectors at the stage of
recruitment.
c) must satisfy the Certification procedures, system, activities and other Certification scope
requirements within the framework of the Certification scope requirements;
d) must attend the GMO-Free Turkish Cotton training system (e.g., course, seminars, etc.) provided
by the TRADEMARK HOLDER;
e) must enable the assigned personnel to have access to any and all notices, procedures and
instructions, entrepreneurs to whom sanctions are applied and any other notices, questions and
answers related to the programme to be published in the GMO-Free Turkish Cotton website.
5.1.2.4. Appointment of Personnel
Personnel involved in the Certification procedures, including the committee members of the
Certification Body will
a) follow the policies and procedures of the Certification Body;
b) declare its commercial and other relations with the entrepreneur with whom the
Certification procedures if applicable.
5.1.2.5. Appointment of Committees
The Certification Body will have official rules and structures for the appointment and implementation
of any committee for the follow-up of the Certification process, basing upon the requirements of
subparagraphs 5.1.2.1 and 5.1.2.2 hereof.
5.1.2.6. Use of Subcontractors (Outsourcing)
When a Certification Body decides to have any operation (for instance, inspection) related to
Certification carried out by an external subcontractor, it will make a legally binding contract which
covers any agreed points including confidentiality and conflict of interests. The Certification Body
a) will undertake the responsibility for the subcontracted work;
b) will make the contract directly with the entrepreneur who will be certified (see 5.1.1.2) and make
the final decision for the issuance, maintenance, renewal, extension and revocation of a certificate. It
will not transfer the power for the decisions to be made in the certification.
c) will make sure that the subcontractor
– is competent enough to perform the subcontracted work;
– conducts in compliance with the identified mechanism so that the personnel it employs will not be
directly or indirectly (through another employer) involved in any procedure or product certification
which violates the rule of impartiality;
– commits to the policies and procedures identified by the Certification Body.
d) will monitor the performance of the enterprises with which an agreement has been reached for
the subcontracted work;
e) will review all communication which the external enterprise has made with the subcontractor and
make sure of the accuracy of the work performed;
f) will take corrective actions in case it becomes aware of any violation of requirements related to
any contractual provision or subcontracted operation;
g) will notify the entrepreneur in advance in order to provide the entrepreneur with the right of
objection against the outsourced activities and the subcontracted operations;
h) will provide the TRADEMARK HOLDER with information and follow up the approval before any
work is started in connection with the subcontractor and type of procedure. The Accreditation Body
will be provided with information upon the TRADEMARK HOLDER’s approval.
5.1.3. Impartiality and Objectivity
Presence of objectivity:
Note 1: Objectivity means that there are no conflicts of interest between the parties or that they
have been settled in a manner which they do not adversely affect the activities of the enterprise.
Note 2: Other terms that are useful in reflecting the essence of impartiality are independence,
remotion from conflicts of interest, remotion from partiality, remotion from prejudices, impartiality,
fairness, open-mindedness, even-handedness, candidness and protection of balance.
5.1.3.1. Organisational Structure and Stakeholder Relationship
Certification Body will be impartial; it will not be materially dependent upon only one of the
enterprises which it has certified in a manner which will impair its impartiality. Particularly, in order
to maintain its impartiality, the Certification Body must
a) identify provisions which will protect its impartiality regarding the certification body activities; and
b) ensure participation of all relevant parties in a manner which will balance their interests and to
prevent any commercial and other interests from affecting the decisions.
5.1.3.2. Impartiality Management
The Certification Body will identify, analyse and document any circumstances of conflict of interest
caused by the Certification provisions including any conflict of interest arising from its relationships.
There will be rules and procedures in place in order to minimise or prevent the risk of conflict of
interest. Particularly, the Certification Body;
a) will require its employees, committee and board members to declare any relationships which they
may previously have with the enterprise to be certified. In cases where such a relationship threatens
impartiality, the Certification Body will exclude any relevant person from any works, discussions and
decision-making activities implemented on the basis of the Certification procedures carried out
depending on the said potential conflict of interest;
b) must identify and pursue ny rules necessary for the appointment and operation of the committees
included in the Certification activities in order to make sure that any decisions made are not affected
by any commercial, financial and/or other internal and external interests.
5.1.3.3. Segregation of Responsibilities
The Certification Body will not provide any services making compromises of its impartiality,
objectivity or confidentiality in its Certification procedures and decisions. In case the Certification
Body is engaged in any other activities in addition to certification, it will take any additional measures
in order to make sure that the confidentiality, objectivity and impartiality of the certification is not
affected by such other activities. Particularly, the Certification Body will not
a) produce or supply any products in the variety of the products which it has certified;
b) give recommendations or provide advisory services to the entrepreneur for the settlement of his
problems related to any circumstances which will prevent the GMO-Free Turkish Cotton Certification
(e.g., nonconformities encountered in the certification process).
Any disclosures as to the GMO-Free Turkish Cotton’s quality assurance system are not considered to
be recommendations or advices; information may be given for the generality of entrepreneurs as
long as it is provided without discrimination.
5.1.3.4. Accessibility
The Certification Body will make any service it renders equally accessible to all applicants as long as
their production activities are related to the services provided.
It must operate in accordance with non-discriminating policies and procedures and make sure that
any improper financial (e.g., for the pricing structure) or other contradictory circumstances (size of
the applicant’s facilities or his membership to any organisation, etc.) are not applied. The
Certification Body will accept all GMO-Free Turkish Cotton inspection appointments notwithstanding
whether or not it is a whole supply chain or parts of the chain or a single procedure.
5.1.4. Access to Information
5.1.4.1. Publicly Available Information
The Certification Body will provide access to information in order to support the integrity and
reliability of the Certification.
The Certification Body will provide the following upon request (via documented publications,
electronic media or other means):
a) GMO-Free Turkish Cotton and its reference documents (GMO-Free Turkish Cotton, Labelling and
Licensing Guide) and other provisions of the GMO-Free Turkish Cotton Certification programme
provided by the TRADEMARK HOLDER (the Certification Body may route one to the GMO-Free
Turkish Cotton website for such documents);
b) Reference information about the procedures to be used in the GMO-Free Turkish Cotton
Certification;
c) Information about the procedures to be referred for the extension of the Certification;
d) Information about the procedures and sanctions to be referred to in case any non- conformity
with the certification requirements are identified;
e) Pricing structure for the services provided;
f) Description of the rights and obligations of entrepreneurs including the requirements and
restrictions;
g) Information about the management procedures of general complaints and objections raised
against the certification decisions.
5.1.4.2. Confidentiality
In order to be able to manage the safety of the access to information, the Certification Body will
make any and all necessary arrangements in order to protect the confidentiality of the information
obtained during the certification activities by the committees, employees and all staff members at all
levels of the body including its related external organisations. Preparations will
a) protect the entrepreneur’s proprietary information against misuse and unauthorised sharing;
b) provide the Certification Body to share information with the other certification bodies,
accreditation bodies and TRADEMARK HOLDER in order to approve the originality of the
information. .
5.1.4.3. Certification Reference and Use of Certification Logo (Trademark)
In line with the provisions of the GMO-Free Turkish Cotton Labelling and Licensing Guide, the
Certification Body must
a) have control over the right of use and mode of use of any certificates, licenses and logos issued by
entrepreneurs;
b) examine and approve the use of the GMO-Free Turkish Cotton logo and label of those
entrepreneurs who have been previously certified. The Certification Body is particularly expected to
– have a proper GMO-Free Turkish Cotton logo and label approval procedure;
– provide label use approval specifically for each and every different design, product group and
producer;
– absolutely make sure that any certified entrepreneur(s) has/have a valid certificate of scope against
such circumstances in which the license number of the entrepreneurs who purchase the products
will be used in the labelling for which an application is filed;
– make sure that the certified entrepreneur provides his non-certified customers with information
about the licensing requirements related to the use of GMO-Free Turkish Cotton label on the product
(as per 5.2 if the non-certified entrepreneur is a processor, manufacturer or B2B merchant; and as
per 5.2 if a retailer);
c) be able to require an entrepreneur to cease the use of the certificates and logos which he
approves the certified entrepreneurs to use;
d) have proper activities and sanctions in place in order to prevent any incorrect or incomplete
references to the Certification system, certificates and the GMO-Free Turkish Cotton logos and labels
which he approves for use by the certified entrepreneurs.
5.1.5. Quality Management System
5.1.5.1. General
a. The Certification Body will establish, document and implement a quality management system in
line with the relevant provisions of these requirements in order to ensure confidence in its capability
of making GMO Free Turkish Cotton Certification. The quality management system will be effective
and compliant with the type, scope and volume of the work performed.
b. The management will make sure that the quality management system is understood, implemented
and maintained at all levels of the organisation.
5.1.5.2. Management System Guide
a) The Certification Body will establish the applicable procedures via a guide or relevant documents
in order to implement a uniform and consistent assessment and use them in its assessments.
b) The guide and relevant documents takes into consideration the following, depending on the
number of personnel assigned with the Certification work being performed, type, scope and volume
of the work:
• documentation of its organisational structure in a manner which will show the duties,
responsibilities and powers of the management and other Certification personnel and each
committee;
• identification of the procedures referenced in providing Certification including Certification,
renewal, extension, suspension and revocation by the Certification Body;
• procedures for the recruitment, selection, training and appointment of the personnel of the
Certification Body (such as those under 5.1.2);
• policies and procedures for the objections raised and complaints filed against the Certification
decision; and
• policies and procedures for the assessment of the Quality Management System (e.g., internal
audits, management’s review).
c) The Certification Body will make sure that the guide and other relevant documents are accessible
by the relevant personnel.
5.1.5.3. Document Control
The Certification Body must establish and maintain in its system in order to check its documents
related to its Certification activities. The Certification Body will particularly
a) review the adequacy of the documents through authorised and adequate personnel and approve
the same before it places them in the system;
b) keep the issued documents together with the dates thereof in a list and describe the updating
status in this list; and
c) have control over the distribution of all such documents and prevent any unused documents from
being unintentionally used in order to make sure that the Certification Body personnel are provided
with any proper documents whenever they have to carry out any procedures related to the
Certification Body activities.
5.1.5.4. Keeping and Management of Records
The Certification Body must maintain a recording system (in the form of electronic or hardcopy
documents) in order to demonstrate that the Certification procedures related particularly to such
other documents as application forms, assessment and re-assessment reports and certificate issuance, maintenance, renewal, extension, suspension or revocation are effectively carried out.
b) Records must be described, managed and destroyed to secure the integrity of procedures and
confidentiality of information.
c) Records of the entrepreneur including the inspection records and Certification history must be
kept updated to contain any necessary information as a whole.
d) Records must also be kept for any permitted exceptions, objections and subsequent activities.
e) Records must be maintained for a minimum period of five years or for the period as required by
the law in order to demonstrate the implementation of the Certification procedures.
5.1.5.5. Internal Auditing and Management’s Review
The Certification Body must aim at continuously improving its quality and must be able to
demonstrate that it has achieved this goal. It must carry out any internal audits and implement the
management’s review procedures in accordance with the type, scope and volume of the Certification
service provided.
a) It must particularly review all procedures in a planned and systematic manner at regular intervals
in order to verify that the quality system and procedures are effectively implemented. Performance
assessments carried out at regular intervals must also be a part of this.
b) Period between the audits must be kept short in order to guarantee the quality improvement to
achieve its purpose. Records of the quality audits must be maintained.
c) Performance assessments of the personnel responsible for assessment, inspection and
certification must be carried out once a year.
5.1.5.6. Objections and Complaints
The Certification Body must have policies and procedures in place related to the management of
Certification procedures or for the solution of any objections and complaints which it will receive
from any entrepreneurs or other parties on any matters concerning the same. Certification Body will
particularly
a) take any proper actions following the solution of any objections and complaints; and
b) document any action taken and the effect thereof.
5.2. Requirements for GMO-FREE TURKISH COTTON Certification
5.2.1. Application procedures
5.2.1.1. Information for entrepreneurs
The Certification Body must identify the current procedures which must be referenced in
implementing Certification procedures for entrepreneurs. The Certification Body must provide
entrepreneurs with information on the following issues:
a) Contractual terms and conditions including pricing and potential sanctions;
b) Rights and obligations of the entrepreneur including the appeal procedure;
c) Current version of the GMO-Free Turkish Cotton standard and equivalent documents published by
the TRADEMARK HOLDER;
d) Programme changes including the regular updates of the procedures and standards;
e) Assessment and inspection procedures referenced during certification by the Certification Body;
and
f) The Certification Body must provide the entrepreneur of any documents which must be kept so
that his conformity with the GMO-Free Turkish Cotton may be approved.
5.2.1.2. Application Form and Obligations of Entrepreneurs
The Certification Body must require the authorised representative of the entrepreneur to complete
the application form and deliver it to the Body in a signed manner. In order to make an assessment
and appointment of proper personnel, the Certification Body must receive from entrepreneurs
a) information required by the Certification Body about the required certification scope
including the description of the production, product, facility and subcontractors to be
certified;
b) information about whether or not the Certification Body has previously denied their
applications and about the reason for such denial. In addition, if an assessment has been
made for this standard, then the entrepreneur must deliver a copy of the last assessment
report. In case the entrepreneur has nonconformities not remedied, such nonconformities
must be followed up by the new Certification Body.
c) information about any application which they filed, approval obtained, approvals
suspended or revoked or expired in the past.
5.2.2. Assessment
5.2.2.1. Scope
a) The Certification Body must make a plan for the assessment activities so that any necessary
regulations may be made.
b) The Certification Body must assess the entrepreneurs for all valid Certification requirements.
Assessment is consisted of the review of documents and a field inspection visit.
5.2.2.2. Assessment of Application and Preparation for Inspection
a) Prior to inspection, the Certification Body must review the application documents in order to
make sure that the Certification procedures may be implemented and that the application may be
received depending on the Certification scope.
The Certification Body will particularly review whether or not the following requirements have been
satisfied:
• that the documents presented by the entrepreneur are complete;
• that the entrepreneur seems to be capable of satisfying all Certification requirements (regarding
conformity to the GMO-Free Turkish Cotton and other valid procedures).
b) The Certification Body must appoint qualified personnel for the assessment of the requirements
of 5.1.2 and 5.1.3 above and provide the personnel so appointed with any documents related to the
work to be performed.
c) The Certification Body must provide the inspectors with information about any nonconformities
belonging to the preceding inspection and about any relevant corrective actions required. Inspectors
must follow up the status of the corrective actions on site in order for any remedied nonconformities to be approved.
5.2.2.3. Inspection Protocol
Inspection is carried out in order to assess the information of the entrepreneur and the compliance
with the Certification requirements. A protocol which has been established in order to be able to
carry out an objective inspection without discrimination must be followed.
Field inspection protocol must undertake the following points for the inspected entrepreneur as a
minimum provided that it is valid:
a) It must assess the operating system through inspections carried out in the processing and storage
units (it may also cover a visit to the non-certified areas if it is deemed necessary).
b) Records kept to confirm the product flow and the accounting entries must be inspected
(input/output conciliation and backtrack).
c) Chemical inputs (colorants and auxiliary materials) and the accessories used must be inspected and
their conformity to the applicable criteria of the GMO-Free Turkish Cotton must be assessed.
d) Areas which present a threat to the product integrity must be identified.
e) Waste water treatment plants of those enterprises carrying out wet processing must be inspected.
f) Operator must carry out random sampling and verify the risk assessment of the contamination and
residue testing policy; this must also include taking samples for residue testing in case of suspicion of
potential contamination or nonconformity.
g) Approval of compliance with the minimum social criteria as set forth in the standard. Inspection
protocol must particularly contain the following:
– Inspection of the processing and storage units, toilets, resting areas and other areas accessible by
the employees of the company;
– Interview with the management and confidential interviews held with the employees and the
representatives of employees;
– Review of the list of working personnel, employment contracts, payrolls, shift and working time
protocols, age verification and personnel files such as social security documents.
h) Effective implementation of any modifications and any relevant requirements in the standards
must be confirmed.
i) It must be confirmed that corrective actions are implemented.
5.2.2.4. Special Requirements for High-Risk Situations
The Certification Body will improve and adapt its Certification procedures for high risks existing in
certain situations specific to the GMO-Free Turkish Cotton Certification. Potential high risk situations
and relevant measures must include the following:
a) Parallel processing of certified and non-certified GMO-Free Turkish Cotton products: In order to
prevent the organic products from mixing with or being contaminated by non-standard products, the
Certification Body must approve the documents related to the segregation processes carried out
between the products intended for wet processing, storage and sales and certified and non-certified
products. In cases where the products do not have any visible differences, special measures must be
taken to reduce the risk.
b) In case a certified entrepreneur has been certified by another Certification Body as per a standard
containing similar scopes, then the Certification Body must exchange information with the other
Certification Body in order to prevent the misuse of the certificates.
5.2.2.5. Reporting
The Certification Body must present its assessment findings in the form of a report to the
entrepreneur according to its own procedures. Reports containing the inspection results and, if valid,
the final status of nonconformities must be delivered to the entrepreneur along with the electronic
notification of the certification.
a) Inspection reports must contain the production works performed or the inspection results of the
business system in a format compliant with the type of the inspected enterprise. The report must
have been impartially prepared and must be objective and comprehensible.
b) Inspection report must cover the valid relevant aspects of the standards and confirm the accuracy
of the information provided by the entrepreneur.
The report must contain the following:
– Findings obtained about compliance with the certification requirements;
–Employees interviewed, facilities visited, date and time of the inspection;
– Types of the documents reviewed.
c) The Certification Body must immediately notify the entrepreneur of any nonconformities which
must be remedied for compliance with the valid requirements.
d) The Certification Body must follow up the effectiveness of the corrective actions taken by the
entrepreneur and obtain the documents of the measures taken.
5.2.3. Certification Decision
Certification decisions must be made not later than 60 days following the date of inspection.
5.2.3.1. Segregation of Responsibilities
The Certification Body must make sure that Certification decisions are made by the person(s)
different from the person(s) carrying out the inspection or by the committee.
5.2.3.2. Basis for Decision
An entrepreneur’s conformity to the GMO-FREE TURKISH COTTON Certification requirements
decision is made by using the information collected during the inspection process.
5.2.3.3. Certification
Any evidence constituting the basis for the Certification decisions will also be included into the
documentation.
5.2.3.4. Management of Nonconformities
a) Certification decisions may contain the requirement of remedying any minor
nonconformities within a designated period of time. In cases of major nonconformities, any
Certification decision is not made or suspension procedure may be carried out until the
implementation of the corrective actions is confirmed. In cases of significant
nonconformities, Certification may be denied or revoked.
b) The reasons set forth for the denial, revocation or suspension of the Certification must
expressly state what criteria of the Standard or what other requirements of Certification are
violated.
c) If the reason for the denial or revocation of the Certification is identified as forgery, then
the Certification Body must notify the TRADEMARK HOLDER without delay. The TRADEMARK
HOLDER must notify the accredited Certification Bodies of the sanctions applied to such
entrepreneurs and require them not to provide Certification services for a designated period
of time.
.
5.2.3.5. Exceptions to Certification Requirements
a) There may be practices identified as exceptions to Certification requirements:
There may be an inspection period or other rules determined by the TRADEMARK HOLDER
for those small-sized subcontractors and merchants with lower risk potential.
b) The Certification Body must develop a procedure for any exceptional situations to the
Certification requirements. Causes of such exceptional situations must be disclosed in the
procedure.
5.2.3.6. Issuance of Certification Documents
a) The Certification Body must issue a ‘Certificate of scope as per the draft as specified by the
Standard’ following the making of a Certification decision for the entrepreneur who the
Certification Body inspects.
Any productions and relevant operations carried out the subcontracting enterprises of the
certified entrepreneur will be listed in the annexes to the issued certificate of scope.
b) Validity period of the certificate of scope should not exceed 16 months following the date
on which it is issued.
.
5.2.4. Extension and Renewal of Certificate
5.2.4.1. Continuity of Assessment
a) The Certification Body must regularly re-assess the entrepreneurs in order to check whether or
not they keep complying with the GMO-Free Turkish Cotton. There must be mechanism in place in
order to follow whether or not any corrective actions are implemented.
b) The Certification Body will report and documents its activities related to continuity in its
assessments and provide the entrepreneurs with information about the status of their Certification.
c) R-assessment will usually follow the procedures of which drafts are provided in 5.2.2 hereof (i.e.,
Assessment). However, the re-assessment carried out in order to renew the Certification may focus
on particular measures related to the risk and may not repeat all of the procedures as contained in
5.2.2.
5.2.4.2. Inspection Frequency
a) Entrepreneurs who must usually be certified pursuant to the criteria set forth in the GMOFree
Turkish Cotton (ref. paragraph 4.1) must be inspected once a year as a minimum. Those
merchants who sell and purchase certified products may only be included into the remote
inspection programme. For this purpose, the certification inspection should continue as
follows: at the office in the initial year; remote inspection in the second year; office
inspection in the third year; remote inspection in the fourth and fifth years; office inspection
in the sixth year; subsequently office inspection in every third year and remote inspection in
the two years in between.
b) Cases in which such exceptions as remote inspection will be applied must be identified in
the course of the field inspections carried out.
c) In addition to the annual inspections of the entrepreneurs, the Certification Body must
also carry out inspections without notice. Such inspections must correspond to 5% of the
number of entrepreneurs. Minimum number must be 2 entrepreneurs.
5.2.4.3. Notification of Changes Made by Entrepreneur
a) The Certification Body must require entrepreneurs to notify the Body in case any changes
occur in the information provided pursuant to 5.2.1.2 by them.
b) The Certification Body must decide whether or not the notified changes need to be
examined in more detail. In cases where additional examination is required, the
entrepreneur will not launch his certified products to the market.
c) In case any request for change is made in the content of a certificate of scope already
issued, the Certification Body must decide what assessment procedure it will use in order to
decide whether or not the change is to be made and take action pursuant to such procedure.
5.2.4.4. Modifications in Certification Requirements
a) The certification Body must notify its entrepreneurs of any modifications made in the
Certification requirements without delay.
b) The Certification Body must confirm that the entrepreneur has applied any notified
modifications in due time within the allowed period of application.
5.3. Assessment of Textile Auxiliary Materials (chemical inputs)
Assessments of conformity of any textile colorants and chemicals used in textile enterprises to ZDHC
must be carried out by chemists specialised on the matter who are employed by the Certification
Body.
5.3.1. Application Procedures
5.3.1.1. Information for Entrepreneurs
Assessment procedures of textile chemicals must be carried out pursuant to the criteria set forth in
paragraph 5.3 hereof.
Chemicals and colorants used must have been approved as per the approval procedure of
internationally valid ZDHC and/or Global Organic Textile Standard (GOTS). Approval lists and/or other
relevant evidence must be delivered to the Certification Body for assessment by the entrepreneur.
The said assessment must have been completed at the desk before going out to the field. The
inspector must confirm the products as contained in the chemical lists provided by the entrepreneur
during the field inspections.
The entrepreneur must follow any changes which may occur in the approvals of the said chemicals
and colorants and notify the Certification Body of such changes. Use of those products that have lost
their approvals in the certified productions must be immediately terminated and the Certification
Body must be notified of the names of such products.
.
5.4. Special Requirements for GMO-Free Turkish Cotton Accredited Certification Bodies
5.4.1. Annual Fee
The Certification Body will pay the annual (including the incomplete years) fee to be fixed by the
TRADEMARK HOLDER per facility inspected or certified as stipulated in the Licensing and Labelling
Guide and ‘Certification Body Contract’. The said fee is up to 10% of the inspection fee per
enterprise.
Payment will be deposited to the account of the managing company established by the TRADEMARK
HOLDERS in quarterly terms.
TRADEMAKR HOLDER reserves its right to make modifications in this clause at all times.
5.4.2. Collection of License Fee
The Certification Body will collect the fixed License Fees on behalf of the TRADEMARK HOLDER and
pay such fees to the TRADEMARK HOLDER against invoice in the manner which is stated in the
Licensing and Labelling Guide and ‘Certification Body Contract’
5.4.3. Competition
Accredited Certification Bodies must not compete with one another on the inspection and
Certification fees in a manner which will degrade the quality of the inspection. They must take into
consideration the price list fixed by the TRADEMARK HOLDER on the matter.
Pricing of Certification Procedures are valid for Scope 1 and Scope 2:
Inspection Fee per Enterprise: For Textile, Apparel and Ginning Businesses, Scope and Transaction
certificate fees will be determined according to the annual inflation rate.
5.4.4. Publicly Available Database, Activity Reports
a) Certification Bodies must keep the GMO-Free Turkish Cotton database updated at all times
by entering the required information of the certified entrepreneurs (e.g., names, addresses,
contact information, product descriptions, operating area and validity period of the
certificate).
b) Certification Bodies must send to the TRADEMARK HOLDER a list for the preceding
calendar year of the inspected and/or certified entrepreneurs and those entrepreneurs who
have given up certification in the form of an annual activity report not later than 31st
January.
c) Certification Bodies, upon the request from the GMO-Free Turkish Cotton Technical
Committee, must provide the GMO-Free Turkish Cotton Technical Committee with detailed
information about their inspection and Certification activities. Any activities so provided will
be assesses as to whether or not they are in compliance with the GMO-Free Turkish Cotton
procedure and other relevant guides as well as any procedures, rules and recommendations
issued by the Technical Committee. Members of the Technical Committee will conduct in
accordance with the confidentiality principles for all of such information.
d) Certification Bodies will communicate any complaints regarding the implementation of
the quality assurance and labelling system of the Standard to the complaint assessment
official in order to be able to follow such complaints.
5.4.5. Cooperation with Other Certification Bodies
Member of the Committees of the Certification Bodies work together in cooperation with one
another under the supervision of the Standard Development and Quality Assurance manager so that
the GMO-Free Turkish Cotton Standard will be equally implemented and inspected at international
level

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