Organic Certification Q&A

AQUACULTURE

Can fish and seafood be certified organic? Where can I find more information on this?

Yes, fish and seafood can now be certified organic. More information on this can be found in the recently updated Canadian Organic Aquaculture Standard. All organic products that cross provincial borders must be certified to this standard.

BODY CARE

Am I able to have my body care products become certified organic? What is involved in this process?

As it currently stands body care products are not included in the Canadian Organic Standards, as clarified by the Canadian Food Inspection Agency in 2015. However, OCO is working hard to have them included in the regulations and standards. It is possible to have your body care products certified under US and European standards. The most widely accepted certification for body care products is USDA Organic. Please see our blog post for more information.

Given that body care products are outside the scope of the Canadian Organic Standards, is it possible to have a product claim to be organic and not use the certified organic logo?

Yes, this would be possible. However, to demonstrate third party integrity and build the company brand it would be useful to certify to the USDA’s National Organic Program standards or the standard of another Ontario certification body.

CERTIFICATION & LABELLING

Are all grassfed meat and dairy products sold in Ontario organic?

What is required for me to sell a product that has been certified organic by the USDA in Canada? If a product is certified as organic by certifying bodies outside of Canada, does that mean it is also certified as organic in Canada? Are there additional Canadian certifications I need to aim for?

In order to be able to use the Canada Organic Logo, your product must be inspected and certified to the Canadian Organic Standards by a Canadian accredited certifying body, or, if it is certified under one of the certification regimes with which Canada has an equivalency agreement, this equivalency must be verified by a Canadian certifying body. Unless this certification or verification takes place, your product can still be sold in Canada bearing international organic certification labels, but not the Canada Organic Logo.

The requirements you must meet in order to become certified are outlined in the Canadian Organic Standards, and its accompanying list of permitted substances.

If the product is being packaged or labelled in Canada then you will need to apply for certification through a certifying body.

If the packaged product is simply being imported and distributed in Canada then it is only voluntary that one applies for an attestation of compliance. However, before an American, NOP-certified product can be labelled with the Canada Organic Logo a copy of an NOP certificate verifying compliance with the US-Canada Organic Equivalency Agreement needs to be secured.

What regulations are placed on products labelled organic but that do not bear a certified organic logo?

Canada’s Organic Products Regulations do not apply to organic products that are only sold within Ontario and do not display the Canada Organic Logo. For these products, the CFIA would verify on a complaints-based basis that organic claims are truthful and not misleading, as required under the Food and Drugs Act as well as the Consumer Packaging and Labelling Act. For example, the CFIA inspector may verify the validity of the organic claim by:

  • evaluating the production methods against the company’s organic plan;
  • checking the company’s records; and/or
  • identifying the areas where organic products could be contaminated with prohibited substances and/or come into contact with non-organic products.

However, without certification, this process is difficult for the CFIA to achieve and acts as yet another good reason for regulation of organics within Ontario.

All products labelled as being organic that cross provincial borders must be certified to the Canadian Organic Standards or Canadian Organic Aquaculture Standards.

My product contains only certified organic ingredients. Does this mean I can label my final products as organic? If not, what do I need to do?

You are legally permitted to list which ingredients and/or what percentage of ingredients are organic, on the label. However, if you want your product to bear a certified organic label or wish to call the product itself organic, you will need to first have your product certified by an organic certification body if you plan to market or distribute it outside of Ontario.

What rules need to be followed when buying farmland from a certified organic business if I wish to also have my products grown on this farmland as certified organic?

Unfortunately, an entire farm cannot be certified organic. Instead, only a product can be certified organic. Regulation requires that a person wishing to certify a product as organic must apply 15 months before the product is marketed, even if the previous owner had been certifying crops grown on that land.

If you were to purchase just the farmland then you would need to apply for certification as a new client. You are allowed to rent land from the old owner prior to the completion of the land transfer. In this case you can apply for pre-certification of any crops you wish to grow in order to speed up the process. At the same time the previous owner would need to cancel their certification. If the transfer of property takes place during the growing season it is important that both the buyer and the seller coordinate with the certifying body to ensure that the “chain of custody” stays intact.

If you were to take over the entire business previously operating on the farm, then there would be no interruption in certification. If the former farm owner wishes to rent a portion of the farm from you to continue their business they can continue to operate under their same certification.

There are a few important things to document when buying a farm that has been producing certified organic products.

  1. The exact date when the organic certificate of the previous owner is cancelled.
  2. The date at which management of the fields is transferred to the new owner. This may be different from the sale date of the farm.
  3. What substances are applied to the land during the transition period. It is especially important this is recorded during the period after the previous owner’s organic certification is cancelled.

INPUTS

I have a product that I would like to be included on the approved inputs list. How do I obtain organic certification for this product?

A good place to start is by consulting the. The ACORN Directory of Organic Inputs can be used to determine which portions of the Canadian Organic Production Systems – Permitted Substances Lists apply to your specific product. Different inputs have different registration requirements and not all inputs have to be certified organic. Some inputs just require that they be approved for organic production by a certifying body. Ontario certification bodies provide steps on their respective websites as to how to have your input approved for organic production. Once approved certifying bodies can list them in a public list of approved inputs. Another option is to apply to get included in the OMRI (Organic Materials Review Institute) Canada Organic List.

Biochar is permitted under the Canadian organic standards. Is activated biochar also permitted?

As long as the materials used to activate the biochar are on the Canadian Organic Production Systems Permitted Substances List then activated biochar is also fine. However, as outlined in section 7.5 of the Canadian Organic Standards, if used in a closed container then there is a minimum soil and compost requirement that must accompany the biochar.

Do organic farms in Ontario use any type of biosolid waste or sludge on their crops or farms?

As stated in section 1.4 e) of the Canadian Organic Standards, the use of sewage sludge in organic production and preparation is prohibited since it is incompatible with the general principles of organic production.

I would like to use potassium as an input in my organic farm. Are there limits on the sources from which this potassium can be extracted?

Yes. As outlined in the Canadian Permitted Substances List, certain potassium sources are prohibited. Section 4.2 states that the following potassium sources are permitted:

  1. a) langbeinite, mined sulphate of potash magnesia and mined potassium salts (sylvinite and kainite);
  2. b) potassium rock powder—includes basalt, biotite, mica, feldspar, granite and greensand;
  3. c) potassium chloride (KCl)—muriate of potash and rock potash. KCl shall not cause salt buildup in soil through repeated application;
  4. d) potassium sulphate—shall be produced by evaporating brines from seabed deposits or combining mined minerals. Potassium sulphate made using reactants (such as sulphuric acid or ammonia) is prohibited. Fortification with synthetic chemicals is prohibited.

ORGANIC FRAUD

I have reason to believe a grocery store is selling conventional produce as organic. What can I do about this?

The best way for you to make a complaint about misuse of the organic label in Ontario is to:

  1. Alert CFIA by filling in a report online: Food Safety Or Labelling Concern Form
  2. Get in touch with your CFIA Regional Office.
  3. Alert OMAFRA to your concerns
  4. Copy info@organiccouncil.ca so that we can track how many complaints there are and if they are resolved.  This will help us to better advocate on your behalf and for better monitoring and enforcement.  
  5. Include in the email as much detail as possible including photos, product names and businesses that you are complaining about.  
  6. Please follow-up with OCO on any action (or inaction) that is taken as a result of your complaint so that we may track the outcomes.  

While CFIA is meant to oversee these kinds of issues, if your retailer is only selling products that haven’t passed a provincial border, they may not have enough regulatory power to do so.  Please see our campaign to regulate the word organic in Ontario.

PARALLEL PRODUCTION AND PROCESSING

Is it possible to grow both organic and non-organic products on the same farm?

Yes, this is possible. According to the Canadian Organic Standards, certification is by product. These standards require that there be a rotation plan and a plan for keeping organic and non-organic products separate to prevent co-mingling. In addition, the standards state that parallel production is not permitted for the same annual crop but exceptions exist in some cases (see section 5.1.4 below).

Furthermore, the standards specify:

5.1.3 The enterprise shall aim at a complete transition of its production. During the transition period, the enterprise can maintain, in addition to the production in transition, a non-organic system of production (split operation) that shall be entirely separate and identified separately, pending its incorporation into the overall transition process.

5.1.4 The enterprise can be converted one unit at a time, and each converted unit shall respect the requirements of this standard. The exception to this norm, parallel production, is only allowed in the following cases: perennial crops (already planted), agricultural research facilities and production of seed, vegetative propagating materials and transplants.

Is it possible to process both organic and non-organic products in the same facility?

Yes. If you’re a processor, parallel processing is allowed as long as organic and non-organic are processed and manufactured in two separate lines in the facility and documented separately. In the case of livestock production it is required that you have two separate production facilities.

PORK

What is meant by pasture-raised pork?

An animal that has been pasture-raised has received a significant portion of their nutrition from land covered with grass and other low lying plants. However, pigs require ample protein in addition to the nutrients derived from feeding on pasture. The proportion of a pasture-raised pig that comes strictly from grass depends on the far and its practices.

There are currently no standards or verification process for the use of the term ‘pasture-raised’ on pork products.

STANDARDS TECHNICALITIES

What building materials do I need to be wary of when constructing an organic processing facility? For instance, does it matter what kind of drywall I use?

The organic standards only address food-contact surfaces and materials. As long as your products do not come into contact with other surfaces the materials used are not likely to affect your organic certification.

The following portions of the Canadian Organic Standards also apply:

7.3.1 c) For new installations or replacement purposes, lumber treated with prohibited substances shall not be used in structures, containers or other surfaces that come into contact with growth substrate or mushrooms.

7.5.7 Plants and soil, including potting soil, shall not come into contact with prohibited substances, including wood treated with prohibited substances.

8.1.1 Preparation materials, such as counters, containers and conveyors, in contact with food shall be clean and of food-grade quality.

Are there restrictions regarding what kinds of cans can be used to package organic materials?

Currently, the Canadian Organic Standards do not specify packaging requirements for cans.

How much of a buffer needs to be left between an organic farm and a conventional farm or a timber plot?

The Canadian Organic Standards contain the following sections relevant to spraying near an organic farm:

5.2.1 Measures shall be taken to minimize the physical movement of prohibited substances on to organic land and crops from:

  1. a) adjacent areas;
  2. b) equipment used for both organic and non-organic crops.

5.2.2 If unintended contact with prohibited substances is possible, distinct buffer zones or other features sufficient to prevent contamination are required:

  1. a) buffer zones shall be at least 8 m (26 ft 3 in.) wide;
  2. b) permanent hedgerows or windbreaks, artificial windbreaks, permanent roads or other physical barriers may be used instead of buffer zones;
  3. c) crops grown in buffer zones shall not be considered organic whether or not they are used on the operation.

My neighbour would like to install drainage pipes under the fields of their conventional farm. Will this impact my ability to have my products certified organic?

No, fortunately this will not have any effect on your ability to have your products certified organic.

I am hoping to start an organic farming business in Ontario. Can I import material and equipment from outside of Canada to build a greenhouse?

Yes, imported building materials are fine to use. The Canadian Organic Standards only address food contact surfaces and materials. However, if these imported materials will be in contact with the food then the Standards outline several details that are important to keep in mind.

7.3.1 c) For new installations or replacement purposes, lumber treated with prohibited substances shall not be used in structures, containers or other surfaces that come into contact with growth substrate or mushrooms.

7.5.7 Plants and soil, including potting soil, shall not come into contact with prohibited substances, including wood treated with prohibited substances.

8.1.1 Preparation materials, such as counters, containers and conveyors, in contact with food shall be clean and of food-grade quality.