Canadian Organic Standards
Updated September 10, 2008
(Early General Election information added 9/10/08, CCOF Conference calls recording information added 8/28/08, OTA Canada Seminar added 8/25/08, Proposed COR transition Policy added 8/22/08, CCOF Canadian Standards Review Letter added 8/22/08, GMA application forms added 8/20/08, conference call information updated 8/12/08, wine issues added 8/4/08):
Overview | How Does This Affect Me & What Should I Do | What CCOF is Doing | Conference Calls | Implementation Process & Transition | Standards Issues of Note | Regulatory Bodies in Canada | Complete Standards | Additional Information Sources
Overview
Effective December 14, 2008 Canada will implement new organic standards under a series of regulations, organics standards and administrative rules referred to as the "Canadian Organic Regime" or "COR". Click here for a description of the standards and bodies who make up the COR. Canadian authorities are stating that all products sold between provinces or entering Canada should meet the COR after this date. According to Canadian authorities, there will be a transition period for products in the "stream of commerce" but all newly produced and exported products will have to meet the Canadian Organic Standards. It is unclear what the final policy will be for Canadian organic imports after December 14, 2008 as key standards are under revision and a final transition policy has not been publicized. Therefore, it is in the best interest of affected CCOF clients to begin analyzing their operation's compliance with these standards.
Early General Election
On Sunday, September 7, the Prime Minister of Canada called for an early general election which will be held on October 14, 2008. This means that all Canadian regulatory processes, including the Organic Products Regulation (OPR), will be on hold until after the election, which may impact the December 2008 implentation date.
Additionally, CCOF has recently learned that the Canadian organic standards will mosly likely incorporate the exising bilingual labeling laws, which require almost all language on food labels to be in both English and French. Therefore, if the term "organic" is used on a label, the phrase "biologique" will also be required to appear. CCOF recommends that all members exporting to Canada become familiar with Canadian labeling laws, which can be accessed at the Canadian Food Inspection Agency (CFIA) website.
CONFERENCE CALLS ANNOUNCED:
CCOF held a series of conference calls with CCOF members and the organic community to address concerns and organic certification issues relating to these changes.
Call times, dates and how get recordings:
August 27th, 2008: For CCOF members only to address specific standards and CCOF organic program issues including, what CCOF clients need to do to request review to Canadian standards.
August 28th, 2008: Open to non-CCOF members and interested parties to discuss the upcoming regulations, who is affected, and general standards issues.
CCOF clients and members of the organic community may request a link to a recording of these calls by contacting canada@ccof.org. Please indicate which date you're requesting and identify your company name and/or CCOF client code in your request.
How Does This Affect Me & What Should I Do?
CCOF certified operations who ship products directly to Canada or sell products that eventually are shipped to Canada by others (as ingredients or through brokers or resellers etc.) may be asked about their compliance with Canadian standards in the near future. Although transition policies or US/Canada equivalency MAY occur at some point, CCOF is offering a certification program for Canadian standards to ensure a minimum of market disruption.
- Enroll immediately in CCOF's Global Market Access program to ensure your operation is reviewed against the new Canadian standards.
- Review standards difference and issues below.
- Read the new CCOF Manual 3: A Guide to Global Market Access. Review the sections addressing Canada and assess your compliance.
- Participate in the CCOF Canadian Organic Program conference call with CCOF on August 27, 2008 at 10am. Request a recording by emailing canada@ccof.org. Please indicate your client name and code when requesting your link. Additional calls TBA in December and January.
- Review CCOF's new Canadian Organic Standards Review letter. (e-form word version). This document explains the process for requesting immediate review to Canadian organic standards and associated costs.
- Complete CCOF's new Global Market Access program application for your type of operation. Complete ALL sections and indicate "Canada" on first page. Submit to CCOF immediately. Application Forms:
PDF Versions: GMA-Grower | GMA-Handler | GMA-Livestock
E-Form Versions: GMA-Grower | GMA-Handler | GMA-Livestock
- Notify CCOF during inspections and at canada@ccof.org that you require review to Canadian standards. CCOF will utilize these requests to prioritize our Canadian standards reviews of CCOF clients and to ensure you receive key communication on Canadian issues.
- Wherever possible, implement compliance measures to meet Canadian requirements.
What CCOF is doing:
CCOF will inspect to all known and reasonably expected Canadian standards (see specifics below) beginning in August 2008 under our existing Global Market Access program. Read CCOF's NEW Manual III including new Canadian Standards Requirements. CCOF has revised its Global Market Access program to include Canadian compliance section in a new GMA application.
New GMA applications and the Canadian Organic Standards Review Information letter are being mailed to all CCOF clients in late august (both of these can be downloaded above). These applications may be submitted by any CCOF certified operation for review to Canadian organic standards. During upcoming reviews CCOF will make you aware if you comply or if specific changes have to be implemented to meet the Canadian requirements.
Wherever possible, CCOF will identify operations, fields, products, and crops, and operations that meet the COR standards. CCOF may implement document review or other information gathering measures to ensure Canadian compliance for operations that are already certified and have been inspected in the last year.
Where CCOF knows key standards are under revision, we will notify CCOF clients of a potential COR compliance issue and await finalization of the standard. Functionally, it appears that CCOF operations should be preparing to address COR issues and will be required to bring their operations into compliance during the transition period as soon as final standards are produced by the CFIA.
Operations who require Canadian compliance before December 14, 2008 should follow the steps above and notify CCOF at canada@ccof.org ASAP. Operations approved by CCOF under Canadian standards may not use the Canadian logo until it is finalized and the implementation date is reached.
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Certification Standards: Implementation Process & Transition
While the CFIA has stated that the regulation and standard become effective on December 14, 2008, the implementation process and standards have not been finalized. Therefore, there are very few operations certified outside of Canada to these standards. Currently a set of 2006 standards are available but the CFIA is also sending a variety of standards changes ballots out for voting AND will also be adjusting their official logo prior to the current implementation deadline.
As of 7/14/08 CCOF is aware of four separate extensive revision ballots being sent out to the Canadian Organic Sector for comments prior to finalization of the Canadian Organic Standards in late 2008. These ballots contain key provisions regarding manure use, full farm conversion to organic, materials specifications, rules regarding labeling, and standards for sanitizers and other additives. The Organic Trade Association has provided the text of some of these ballots to members as they've been voted on and passed. CCOF has also been told that a final standard and logo will be released in November, 2008.
Visit the CFIA Organic Program web site for more information on the standards and implementation process.
Based on this process and timing, CCOF is concerned that operations sourcing from several suppliers or farms are likely to face significant challenges ensuring their entire supply chain meets Canadian standards. A transition committee is recommending a transition policy to CFIA but it is unclear what the final policy will be. It is possible that products produced prior to Dec 14, 2008 will be accepted into Canada. However, it is not clear how operations that are currently under certification systems and harvesting products or ingredients after Dec 14, 2008 will be handled. While, the transition policy submitted to CFIA would alleviate many issues, it is unclear what provisions in the suggested policy will be adopted and when an announcement will be made by CFIA.
The USDA National Organic Program and others are actively negotiating an equivalency agreement with the Canadian authorities. A number of meetings have taken place and Canadian Food Inspection Agency (CFIA) officials have indicated their interest in reaching equivalency. However, it is not likely that an equivalency agreement will be reached prior to implementation.
Accreditation Bodies
At this time, the CFIA has only released a list of preliminarily approved accreditation bodies and accredited certifiers. CCOF is currently included on the preliminary list of certifiers accredited to provide certification under the Canadian Organic Regime.
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Standards Issues of Note to CCOF Operations
General | Grower | Processor/Handler | Livestock
General Standards Issues back to standards Issues | Back to top
- Many elements and the overall goal of the US NOP standards are present in the Canadian standards but they also contain a number of key prescriptive provisions that are similar to European standards.
- CCOF operations that are enrolled in CCOF's Global Market Access (GMA) program and have achieved either IFOAM or EEC 2092/91 compliance are well on their way meeting COR standards.
- At this time there is no mutually agreed upon gap analysis identifying all the key differences between the US, IFOAM or EEC 2092/91 and Canadian standards. CCOF is developing this now and will use it as the basis for our Canadian standards inspections, and Manual III. CCOF's approach to Canadian organic standards will likely be to integrate additional requirements into the existing Manual III and provide Canadian inspections under our existing GMA program.
- To produce a product in compliance with COR all ingredients must be compliant. With only a preliminary list of certifiers released in mid-2008, it is likely to be late-2009, or later, before the entire US or international supply chain is inspected to Canadian standards. Unfortunately, it may take longer for some operations and their vendors to come into compliance. This may significantly affect sourcing of ingredients or supplies etc.
- The CFIA have received a transition systems proposal from the Canadian Organic Sector but have not yet announced what US and other businesses can expect. An 18 month implementation period is possible and CCOF expects that ingredients on hand and finished products produced prior to Dec 14, 2008 will be able to be shipped to Canada. While this is a concern, CCOF is especially concerned about fresh products and ingredients harvested after Dec 14, 2008.
- Sprout production requires the use of no added sanitizers, which conflicts with FDA recommendations and common practice in the US. This may affect the ability to sell sprouts and sprout products, such as freeze dried powder to Canada.
- Products exported to Canada that include the Canada Organic seal may have to bear an indication of "imported product".
- The Canada Organic seal/logo is currently under revision to remove the word "Canada" in order to avoid confusion regarding its use on non-Canadian organic products. A new Canada Organic seal is expected to be released in late 2008. Use of the new seal will be optional for products with 95% or more organic ingredients. The logo is prohibited for 70%-95% organic ingredient products.
Grower Standards Issues back to standards Issues | Back to top
- Manure from landless operations (so called "factory farms") is prohibited for use in organic production. Operations may have to demonstrate that organic manure is unavailable before using non-factory farmed manure for fertilization. Current standards include this provision but recent approved ballots include modified requirements.
- Inspections must include visits and review of both organic and non-organic areas/fields when both organic and non-organic farming occur at the same operation. It is unclear how this provision should or will be implemented but it is clear that CCOF GMA inspections will need to include visits to nearby or adjacent non-organic fields and crop harvesting or storage locations.
- All annual inspections will have to include written yield estimates.
- Chilean Nitrate is prohibited for use with crops grown for Canada.
- Conversion standards and split/parallel production standards are not finalized yet. Currently, it appears that all land must be free from prohibited materials for 36 months. Additionally, CCOF operations must be under a monitored conversion for a minimum of 12 months with CCOF or another entity such as a State Organic Program etc.
- Operations growing the same crops organically and non-organically may face standards challenges. These standards are under revision and it is unclear where they will end up. The 2006 standard includes a prohibition on growing the same variety organically and non-organically and requires written plans to bring entire operations under organic management. CCOF operations may have to implement separate business entities if they are engaged in parallel production. Operations growing different varieties organically and non-organically, may have to undergo inspections to non-organic sites etc. It is unclear whether the "whole farm conversion" clause requiring operations to convert all ground to organic in a defined time period will remain in the final standard.
- Where required buffer zones must be a minimum of 8m wide.
Processor Standards Issues back to standards Issues | Back to top
- Products with 95%-100% organic ingredients may be labeled "organic" and must ID the certifier. They may include CCOF's seal or the Canada Organic logo, but neither is required.
- Products with 70%-95% organic ingredients MUST be labeled with "Contains X% organic ingredients" to indicate the organic status of the product. These products must also ID the certifier but may not be labeled "organic". They may use the CCOF's seal but not the Canada Organic logo.
- Wine labels: Canadian rules for organic wine labels are similar to US NOP requirements. Wines produced without added sulfites may be labeled "organic", use the Canada Organic Logo, and/or the CCOF logo. These wines should not require any label revisions to access the Canadian organic market but will have to be produced with grapes certified to Canadian Organic Standards. Wines with added sulfites adhere to the 70-95% organic labeling requirements. Specifically, they must use the phrase "Contains x% organic ingredients" or "contains x% organic grapes" and may use the CCOF seal but not the Canada Organic Logo. Therefore, in addition to requiring the use of COR certified grapes a label text change will be required for organic wines with added sulfites marketed in Canada. Note that it is expected that previously produced wines and wines from the 2008 organic crush are generally expected to be allowed for sale under a transition policy. However, this has not been finalized.
- Labels for products from Canadian and Foreign meat, poultry, and processed fruit and vegetable facilities must be registered with CFIA Formulation and Label Registration Unit. These may be submitted using form CFIA 1472 accompanied by labels and formulations. Fees may be applicable, consult the CFIA fees notice for more information.
Mail completed registration forms to: Clerk, Label Registration Unit, Canada Food Inspection Agency,
1431 Merivale Road,
Nepean, ON K1A 0Y9.
- Non-GMO or GMO free statements must be supported by independent tests.
- The COR PSL, standards, and various ballots contain a series of provisions affecting the use of sanitizers, disinfectants, detergents, and pest control materials at the processing level. It is unclear whether food contact sanitizers such as chlorine, hydrogen peroxide, peracetic acid, citric acid etc. will be allowed in wash water for fresh produce and other products.
- The standards include several provisions regarding double rinsing of equipment and also a proposed set of allowed soaps and detergents. Specifically, soaps must be biodegradable and all materials used, including those that do not contact food, must be on the PSL. This area of the standard is identified in the standard itself, the PSL and various ballots. CCOF will require compliance once finalized.
- Additional ingredients, additives and processing aids MUST appear on the Canadian Permitted Substances List (PSL). Potential materials issues identified by CCOF include:
- Calcium Sulfate and Glucono Delta Lactone are both not specifically allowed. May negatively affect the ability to produce COR compliant tofu products etc. Magnesium Chloride is allowed.
- Calcium Hydroxide is prohibited.
- NOP allowed boiler chemicals (allowed under NOP as boiler water additive for packaging sterilization) may not be allowed and is currently under review by CCOF, including: Cyclohexylamine, Diethylaminoethanol, and Octadecylamine.
- There are differing standards for sanitizers and disinfectants such as chlorine, ozone, and peracetic acid between the Canada PSL and various ballots out for voting. To be finalized once standards are completed. CCOF will notify of potential issues and require compliance once COR is implemented fully.
- Lecithin used in COR products must be from organic sources. Bleached forms are allowed if unbleached is not available. Unclear if it is possible to source bleached lecithin from an organic source as certification for bleached lecithin is not possible.
- Sodium Acid Pyrophosphate appears to be prohibited. This common additive in baking may pose a challenge to some operations producing baked goods, especially cookies.
- Allowed processing aids and additives that can be detected through analytical testing in the finished product must be identified on ingredient panels.
- In general products added to the NOP National List since 2003 are not included in the Canadian standards.
- Products packaged for private label customers must identify the certifier and co-packer if the private labeler does not maintain their own organic certification.
Livestock Standards Issues back to standards Issues | Back to top
- CCOF is currently analyzing the Canadian Livestock Standards. At this time it appears that they are similar to NOP standards with some additional prescriptive requirements. However, they also contain allowances that may affect the compatibility of Canadian Dairy/Meat Production with US NOP standards. In other areas it is apparent that the intent and final results of the Canadian livestock standards are markedly similar to US NOP requirements. These issues include:
- Allowance for 80/20 organic/non-organic feeding.
- Limited allowances for antibiotic use with prescribed withdrawal periods.
- Apparent potential for ongoing transition or integration of non-organic replacements.
- Difference between US and Canadian organic livestock standards that affect CCOF producers include:
- Formal written plans should be established for disease outbreaks.
- Housing must have non-slip floors and may not use slatted or grid flooring.
- Calves may only be housed individually for 3 months and must be on pasture at 6 months.
- Open air poultry runs should be vegetated and left empty to allow regrowth. Reseeding should occur as needed.
- Electric prods are explicitly prohibited in transportation and slaughter.
- Herbal and homeopathic medications must always be tried prior to allelopathic drugs.
Regulatory Bodies that make up the COR back to standards Issues | Back to top
- Canada Organic Office: Michel Saumur, National Manager,
Tel: (613) 221-7165/ Fax: (613) 221-7296, msaumur@inspection.gc.ca,
Canadian Food Inspection Agency
159 Cleopatra Drive, Ottawa, ON K1A 0Y9
- CFIA- Implements standards, approves accreditors and accredits certifiers (with accreditor recommendation), negotiates equivalency agreements.
- Accreditation Bodies
- Certifiers- CCOF and others within and outside of Canada.
- Canadian General Standards Board- Develops standards and materials lists as part of public consensus-based process. Composed of several working groups: PSL, Crops, Livestock, Processing.
Standards back to standards Issues | Back to top
Additional Sources of Information back to standards Issues | Back to top
- Organic Trade Association (OTA) and the OTA Canada office. The OTA has been working to keep the US organic market informed regarding the Canadian organic program and is one of the best sources of information with a US perspective. They are facilitating a Canada/US equivalency task force that CCOF is participating in on behalf of our members.
- OTA Seminar on Canadian Organic Standard: OTA will be hosting a seminar called "The Canadian Organic Standard: What you need to know" on Thursday, October 16, from 3-4 p.m. in the Boston Convention and Exhibition Center, Level 2, Room 257A, during Natural Products Expo East. The session will provide the most up-to-date information on the major differences between the U.S. and Canada organic standards, which will be implemented on December 14, 2008. You will have an opportunity to learn how to comply with the Canada Organic Standard and the Stream of Commerce Policy. Speakers will explain the timeline to complete compliance. Speakers include Matt Holmes, Managing Director of OTA in Canada, and Katherine DiMatteo, Senior Associate at Wolf, DiMatteo + Associates.
Please call CCOF at (831) 423-2263 or email us at ccof@ccof.org with any international organic marketplace questions. |
