Answers to some Standards questions generated by COABC's Accreditation Board
Here is an assortment of more in-depth COABC AB Q&As organized by topic. Updated as of August 5, 2015.
Standards Interpretation Q&As
Q1. Can I feed the buffer crops on my land to my young heifer calves?
A. Certified organic farmers may not feed buffer crops to their herd; buffer crops are considered non-organic crops.
Q2. When can a dairy farm feed non-organic or transitional crops?
A. There are three circumstances where it is permissible for dairy cattle to use non-organic feed. First during the transition of a conventional dairy herd, conventional crops from the land transitioning may be fed, following the prescribed standards in the Can/CGSB 32.310 (Section 6.3.1- 6.3.3). Secondly during a farm-scale catastrophic event (Section 6.4.1(a)) and third during a regional forage shortage (Section 6.4.1(b)) but only to the heifers and bulls.
Q3. What is the wood treatment commonly used in BC on plywood harvest bins (e.g. red apple bins) and is it acceptable in a certified organic production system?
A. Plywood harvest bins purchased from Vernon based Tolko Industries are dipped in a red, water-based and food-safe latex paint. The paint is used to seal the wood and preserve it against the elements. These bins are acceptable in organic production systems. Growers may request a copy of the paint MSDS and safety information from the company. Growers may also request to have the bins left unpainted, which may be less expensive but is likely to reduce their longevity.
Q4. Does the Canada Organic Standard allow boiler chemicals for use in certified organic processing facilities?
A. Organic food products cannot be exposed to substances prohibited by section 1.4 of the Standard (prohibited substances, methods or ingredients). If boiler water treatment compounds are volatile, or will carry over into the steam and contact organic products, then these treatment compounds would not be allowed unless they were specifically listed on the Permitted Substances Lists. If there is no risk of product contact, the substance would be allowed.
Labelling Q&As relevant to the British Columbia Certified Organic Program
Q1. I'm a BC-based coffee roaster and packager. Do I need to be certified organic to claim "organic coffee" on my label, if I want to sell my coffee beans only in BC?
A. As of September 1, 2018 the term “organic” is a protected label within BC. In order to claim “organic coffee” on your label your roaster must be certified organic through a Certification Body accredited to the BC Certified Organic Program, or to the Canada Organic Regime.
Q2. An operation has an existing number of plastic produce bags printed with the phrase "certified organic" that they would like to use up to pack peas mainly for the local/BC market. Is it ok to use these bags if the produce is shipped outside of BC?
A. The phrase "certified organic" may be used on product certified under the BC Certified Organic Program for sale within BC. It cannot be used on products certified to Canada Organic Regime (ISO accredited CBs). COABC and the CB are responsible for ensuring that packaging meets these requirements.
COABC is also encouraging all producers to use the BC Checkmark with the phrase "certified organic" - rather than simply listing the phrase on the package. This is to help avoid potential problems with labelling and to clearly inform consumers that the product being sold is certified organic.
The symbol or phrase can only be used IF:
- Your enterprise has a current, valid BCCOP certificate from a certification body accredited under the Regional or ISO program by COABC.
- You have signed the "Consent Conditions". This is a legal document that details the contract between the organic operator and COABC/BCMAL and sets out the conditions attached to the use of the phrase, British Columbia Certified Organic and the Program
Q3. What type of organic claim may BC farms in transition use when selling in BC?
A. Transitioning farms or "farms in conversion to organic" selling all their products within BC may identifying their products as "transitional" or "in conversion to organics" or other similar language on all marketing materials including websites signs and labels.
But they cannot refer to their operation or transitional products as "organic", "organically grown", "organically raised", or "organically produced".
Labelling Q&As relevant to the Canadian Organic Regulations
Q1. How far does the responsibility of the Certification Body (CB) extend when verifying the accuracy of a label to the COR?
A. The CB only needs to ensure that the organic elements are correct. This includes organic claims in both official languages (French and English) and that the logos have been applied correctly, for both the Canada Organic Logo and BC Checkmark. The CB should also verify the CB identifier information is accurate. CFIA only requires the CB be identified, while Quebec requires "certified by..." prefix the CB name.
If the product is being shipped internationally, organic claim requirements for the destination country must also be assessed for compliance.
Q2. I am importing a food product to manufacture a jelly using both imported and local fruit; does the final product require a statement about the country of origin on the label?
A. No. According to federal guidelines for "Product of Canada" and "Made in Canada" products manufactured in Canada, such as this jelly, qualify as ``Made in Canada`` as the last substantial transformation of the product occurs in Canada, even if some ingredients are from other country's products. The package could include consumer friendly language outlining the origin of the product. In this circumstance "made from imported and domestic ingredients" or something along those lines would be appropriate.
When a food product is wholly manufactured outside of Canada, the label must show that the product is imported. In such circumstanced the Organic Products Regulations (OPR) (Section 25c) requires that the statement "Product of..." be printed, immediately preceding the name of country of origin or that the statement "Imported" be used in close proximity to the Canada Organic Logo. Close proximity would infer that the printing appear "near" or "next to" the statement so that it can easily be read on the same panel, not on opposite side of the container, for example.
Q3. What type of organic claim may "transitioning" or "in conversion" BC farms use when shipping products outside of the province?
A. Under COR no organic claims or logos are acceptable. This includes labels, promotional materials and signage.
Certification processes Q&As relevant to the British Columbia Certified Organic Program
Q1. What type of records do small mixed farms that sell within the province need to satisfy the overall inspection process?
A. Regionally certified farms are required to have an organic management plan (also called an organic system plan) which is created/updated on an annual basis. The Regional certification bodies generally provide each farm with a template to fill out upon application/renewal of their annual certification. The plan includes a description of the farm's land base, product(s) produced, including type and numbers of livestock raised and information about their housing and feed rations, a detailed farm map clearly showing boundaries and buffers, crop rotation plans, a list of inputs used or intended for use (seed, fertilizers, compost, etc.).
Annual livestock records should include: the flock or herd numbers and quantity of livestock sold during the year. Feed records (e.g. amount of feed purchased for different types of livestock and the number of hay bales fed) are required, along with information about any inputs used for health care (e.g. vaccines, homeopathic remedies, antibiotics). If compost is made and used on farm, the annual records should also include composting logs for temperature and turning of piles.
The annual crop records should include: organic seed documentation, the application of any inputs used throughout the year, seeding and crop harvest, sales records, and records for crops in storage. Sales records can double as harvest records for fresh produce sold directly to the end consumer.
Q2. What type of records do small mixed farms that sell within the province need to satisfy the audit component of the inspection process?
A. At minimum, sales records that ensure that total sales are reasonable for the scale of the operation should be available for review by the inspector. Inspectors may also want to determine if enough seed or transplants were purchased and planted for the main crops and if the quantity sold of the main crops is reasonable for the area planted.
Certification processes Q&As relevant to the Canadian Organic Regulations
Q1. Is the certification of spirulina acceptable under the COR? Is it acceptable as an organic ingredient (or product) under COR when it arrives in Canada with an USDA National Organic Program (NOP) certificate and United States Canada Organic Equivalency Agreement (USCOEA) compliance document?
A. Spirulina is an aquaculture product, thus currently cannot be certified under the COR. It would need to be listed on the PSL to be permitted as an input/ingredient in organic production. Once aquaculture products are incorporated into the Organic Products Regulations (OPR) then under the agreement with the NOP, it would be acceptable in Canada.
Q2. Has the COR approved the use of the Organic Materials Review Institute's (OMRI) Canada list or Organicinputs.ca?
A. No. There is no process in place under the federal Organic Products Regulations or in the Canada Organic Office (COO) manual for the Canadian Organic Regime (COR) to approve OMRI as a third party certifier of inputs. The OPR is about human food and livestock feed, not brand name inputs. Each Certification Body (CB) has the responsibility to approve inputs for use by their members. If the CB is interested in recognizing OMRI's list, they must do their due diligence to determine if OMRI is reviewing products up to their standard.
Similarly, operators must demonstrate the same due diligence when using the organicinputs.ca directory. They must verify any product or service they intend to use on their organic operation with their specific certifying body before purchasing and/or using that product or service
Certification processes Q&As relevant to both the British Columbia Certified Organic Program and the Canadian Organic Regulations
Q1. Is a poultry slaughter facility exempt from needing organic certification for the slaughter of 'organic' birds?
A. When the slaughter facility is supplying a custom service to a certified operator that is selling their birds within BC only, the slaughter plant does not have to be certified to make an organic claim for the birds but the procedures used within the facility must be verified to demonstrate that the integrity of the organic product is maintained. A regional CB may issue an organic certificate to a slaughter facility. Alternatively verification of the procedures can be done by inspection as part of the certification of the operator, or through an affidavit that covers of all the organic requirements, including an organic plan and audit trail.
When the slaughter facility is supplying a custom service to a COR certified operator so that some the birds can be sold outside of BC, again the procedures used within the facility must be verified to demonstrate that the integrity of the organic product is maintained. Under these circumstances the facility may request an Attestation of Compliance from a CFIA ISO Accredited CB. In other cases verification of the procedures will be completed as part of the certification of the operator.
Click here for more information on the differences amongst certificates, attestations of compliance and affidavits.
Click here to read more Q&As on certificates, attestations of compliance and affidavits.
Q2. What type of signage is allowed on a split farm that has both organic and nonorganic components?
A. A split farm must provide sufficient information in their signage and marketing materials as not to mislead the consumer with a false organic claim. For example, a split farm may not use signage to reference the entire operation as an "organic farm", when for instance the farm produces certified organic vegetables and conventionally grown fruit. In this case, signage indicating "organic vegetables" would be appropriate while "organic fruit and vegetables" would be considered a false organic claim.
Organic product must be clearly identified on the operator's organic management plan and also on the certificate issued to the operator by their respective Certification Body. Operators are encouraged to use the BC Organic Checkmark logo on products for sale within British Columbia. Similarly, non-organic product must also be clearly indicated to the CB to allow the CB to differentiate between the two.
Similarly, split farms must not make a misleading claim through their operation name. For example a split farm may not use the name "Smith's Organic Farm" when the operation is only certified in part, as explained above. The vegetable operation alone may be called "Smith's Organic Farm"; however if the name is to refer to the entire farming operation, "Smith's Fruit and Vegetable Farm" or "Smith's Farm" or another variation, without referencing "Organic" in the name, would be appropriate.
Q3. Is there a transition period for organic processing facilities?
A. There is no set transition period as there is for farm operations, but organic processing must be witnessed during the site inspection before an organic certificate can be issued. Therefore it is common for a processing facility to need two inspections before a Certification Body (CB) may issue a certificate.
This means usually during the first inspection the system and documentation is observed and assessed to see if it is sufficient. This leaves organic processing to be witnessed during the second inspection.
Sometimes organic processing can be verified at the first inspection. And if there are no issues to address, the CB could issue the certificate that would cover the first run.
Click here to review the certification process diagram.
Q4. What type of signage may farms in transition use?
A. A farming operation in transition or conversion is not "organic" and must not mislead consumers with false organic claims. For example, a transitioning farm, certified by a COABC Regional CB, may not call itself "Joe's Organic farm" or use the word "organic" "organically grown", "organically raised", "organically produced" or similar words, including abbreviations of, symbols for and phonetic renderings of those words, in any signage.
The British Columbia Certified Organic Program allows "in transition/conversion to organic" claims on signs, labels and other marketing tools to be used by transitioning operations. However, for operations shipping out of the province, this phrasing is not acceptable to the Canadian Organic Regime.
Neither programs' organic logos may be used by transitioning operations. Check with your CB if they have a transitional logo you can use.
Section 5.1 of the Food and Drug Act prohibits false and misleading claims and applies to all sellers of goods including transitioning farms in BC not under the supervision of a CB selling their goods exclusively within the province.
Section 5.1 of the Food and Drug Act prohibits false and misleading claims and applies to all of sellers of good including transitioning farms in BC not under the supervision of a CB selling their goods exclusively within the province.
Q1. Does my business need to be certified as organic before I can sell organic product?
A. If you are importing ready packed retail product that is properly labeled for the Canadian market, and carries compliant certification document - no additional Canadian certification is required.
If you are making a product or simply repacking or labeling an imported product in Canada then your business needs to be certified.
Q2. What documentation do I need to bring organic product into Canada?
A. Quoting from the CFIA website
Under the regulations, organic products may be imported under the following conditions:
All importers of organic products must be able to demonstrate, at all times, that the imported product conforms to the import requirements set out above.
- Certified to the Canadian Organic Standard;
- Certified as organic in accordance with an agreement, entered into with another country, regarding the importation and exportation of organic products; and
- Certified as organic in accordance with an agreement, described above, by a certification body recognized by a country referred to #2 above.
Q3. Which countries have equivalency agreements with Canada?
A. Canada has Equivalency Agreements with the US, the EU, Switzerland, Costa Rica, and Japan. Agreements with Korea and Mexico are in process.
Even with the Equivalency Agreements, some critical variances have to be addressed
Q4. If a product is imported with ISO/IEC 17065 certification, can I sell it locally and nationally?
A. Refer to A2 in this section. If the ISO/IEC 17065 certificate was issued by a CB that meets the requirement listed in A2 above.
Q5. If a product has an organic certificate that is not recognized by Canada, what information is required to show it was organically grown? Are there tests that can be used?
A. Certification documentation is the only path for compliance. Testing isn't part of the North American certification process. Organic product is sampled and tested by CFIA in their retail-monitoring program.
Q6. If two organic products are imported from different countries and blended together in Canada, can I still make an organic claim? What is the country of origin?
A. If the final product is blended in Canada then the blending procedure must be organically certified in Canada. It is no longer an imported product, but a new product made by blending. The package could include consumer friendly language outlining the origin of the product
Types of certification documents - Certificates, Attestations of Compliance and Affidavits
Q1. What is an affidavit, and when should it be used?
A. An affidavit is a legal statement of fact. It is used by organic operations to verify that goods or lands are as claimed by the provider/neighbour/owner.
Q2. What is an attestation, and when should it be used?
A. Under COR, a CB can issue an "Attestation of Compliance" for a service used by an organic operator. It attests that the service provider is in compliance with the regulations of CAN/CGSB 32.310 and 32.311 and can maintain organic integrity of products passing through its service. An attestation is used rather than a certificate, because it is the service rather than the products being examined; the products passing through do not belong to the service operation. In practice, an attestation is maintained in a similar fashion to certification. The service provider completes an application, including an organic plan and all relevant documentation. Annual inspections are required. CBs determine if the operation complies with the regulations. If the custom operation doesn't hold a valid attestation, a verification officer will need to be on site each time an organic operation engages custom services.
Q3. Are affidavits and attestations used differently for COR and BCCOP?
A. Under COR, and the BCCOP affidavits can be used to verify that seed or inoculant is non-GMO, that trucks are clean, adjacent land was not sprayed, or to verify the field history on newly acquired land.
Under COR Attestations of Compliance are needed for seed cleaning operations and livestock slaughter, transport and storage operations where the organic operation retains ownership of the organic product (seed or livestock).
Under BCCOP, an affidavit may be used to verify that slaughter facilities and other custom services are able to maintain organic integrity. The BBCOP can also issue certificates for service providers if they apply for certification.
Q4. Do operations in transition receive certificates? Attestations of Compliance?
A. Transitional operations under COR may receive status confirmation letters or possibly transitional certificates from their certifier. These documents will not reference the COR or display the COR logo. BCCOP operations will receive CB transitional certificates with no reference to the 'Checkmark' logo or phrase on them.
Q5. What are transaction certificates?
A. Certification documents for a specific shipment generated by a CB upon request by a member. Commonly used for organic bulk commodities.