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Final Questions and answers - Canadian Organic Standards

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Questions and Answers 

Canadian Organic Standards 

CAN/CGSB-32.310-2015 and CAN/CGSB-32.311-2015



General Principles and Management Standards



Permitted substances lists






Questions & Answers

General principles and management standards

1 Scope

1.4 Prohibited substances, materials or techniques in organic production and preparation

3  Terms and definitions

4 Organic Plan

5 Crop Production

5.1 Land requirements for organic production
5.2 Environmental factors
5.3 Seeds and planting stock
5.4 Soil fertility and crop nutrient management
5.5 Manure management


5.1 Land Requirements for Organic Crop Production

5.2 Environmental factors

5.3 Seeds and planting stock

5.4 Soil fertility and crop nutrient management

5.5 Manure Management


6  Livestock production

6.1 General
6.2 Origin of livestock
6.3 Transition of livestock production units to organic production
6.4 Livestock feed

6.5 Transport and handling

6.6 Livestock health care
6.7 Livestock living conditions
6.11 Additional requirements for cattle, sheep and goats
6.12 Additional requirements for dairy cattle housing
 6.13 Additional requirements for poultry
6.14 Additional requirements for rabbits


6.1 General


6.2 Origin of Livestock

6.3 Transition to livestock production units to organic production

6.4 Livestock Feed


6.5 Transport and handling


6.6 Livestock Health Care

6.7 Livestock living conditions

6.11 Additional requirements for cattle, sheep and goats

6.12  Additional requirements for dairy cattle housing

 6.13 Additional requirements for poultry


6.14 Additional requirements for rabbits




7  Specific Production Requirements

7.1 Apiculture

7.2 Maple products
7.3 Mushroom production
7.4 Sprouts, shoots and micro-greens production
7.5 Greenhouse crops 
7.6 Wild Crops

7.1 Apiculture

7.2 Maple products

7.3 Mushroom production

7.4 Sprout, shoots and micro-greens production

7.5 Greenhouse crops production

7.6 Wild Crops


8  Maintaining organic integrity during cleaning, preparation and transportation

8.2 Cleaning, disinfecting and sanitizing

8.3 Facility pest management and post‐harvest  management

9 Organic product composition



Permitted substances lists

General information

Brand name approval


Table cross-referencing

About ‘Origin and usage’

Annotations to permitted substances


4  PSL for crop production

Table 4.2 Soil amendments and crop nutrition

Table 4.3 Crop production aids and materials


5  PSL for livestock production

Table 5.2 Feed, feed additives and feed supplements

Table 5.3 Health care products and production aids


6  PSL for preparation


7 PSL for cleaners, disinfectants and sanitizers


General principles and management standards

1 Scope

1.4 Prohibited substances, materials or techniques in organic production and preparation

GMOs – Substrates and growth media

Can inputs, which have been produced using substrates from GE plants, be used in organic food production? (88) 

Yes and no. Inputs from GE plants are prohibited with the following allowances for input substrates (growth media). 

If the substance (input) includes the substrate or growth media, the ingredients contained in the substrate must be listed on Tables 4.2 or 4.3 for crop inputs; 5.2 or 5.3 for livestock inputs and 6.3, 6.4 or 6.5 for prepared products. All substance annotations apply. If the substance does not include the substrate or growth media, and that is confirmed in writing from the supplier, the substance has to have been produced on a non-GE substrate or growth media, if commercially available. Refer to 4.1.3, 5.1.2 and 6.2.1 of CAN/CGSB-32.311.


Visually indistinguishable

What is the criteria or definition for “visually indistinguishable” (3.46)? Is a crop considered visually distinguishable if can be identified by an expert such as a grader or plant breeder OR must it be visually distinguishable to a common person? (349)
The criteria for 'visually indistinguishable' is that a common person could not distinguish one from the other if the products were positioned side by side.


Mutagenesis - cisgenesis

Do seeds resulting from mutagenesis or cisgenenis fall within the Standard's prohibition of Genetic Modification? (255)
Mutagenesis and cisgenesis are not prohibited by the Standard. The use of these techniques is limited to combining plant materials that will cross or breed through natural processes"


3 Terms and definitions 

Genetic engineering – Cell fusion

Is cell fusion allowed in organic production? (199)
No. Cell fusion which combines plants of different taxonomic families (such as sagebrush and grape) is not allowed. Cell fusion is only allowed between members of the same taxonomic family. See the definition of 'Genetic Engineering' in Section 3.


What is the definition of biodegradability as it pertains to the Canadian Organic Standards? (263)
Biodegradable is defined in the standard as “capable of microbial decomposition within 24 months in soil (with the exception of plant biomass), one month in aerated water, two months in anaerobic water, with minimal impact on the environment” (see 3.10 in CAN/CGSB-32.310).


Definition of ‘production unit’

What is the definition of production unit for agricultural enterprises? Does each field or each greenhouse, each livestock building constitute a production unit or is it all fields, greenhouses, buildings managed by a company? (403) 
A production unit is defined as "identifiable portion of an operation in which production or preparation of an organic product occurs." Therefore, each field, greenhouse, or livestock building - even a contiguous portion thereof that is identified separately in an operation's organic system plan - would be considered a separate production unit if requirements pertaining to segregation, traceability, buffer zones, organic integrity, etc. were maintained for that identifiable portion. All production units shall have distinct, defined boundaries (5.1.6 in 32.310).


4  Organic plan

Recordkeeping – Format

Is there is a specific format required for recordkeeping? (100)

No. There is no specific format for record keeping prescribed in the standard.  Records must be readily auditable and contain sufficient detail to satisfy the requirements of 4.4.     


Records for short-shelf life products

Do operators producing short-shelf life products need to keep 5 years of daily production records to satisfy 4.4.5 of CAN/CGSB 32.310? (469) - December 2, 2019









5  Crop production 

5.1 Land requirements for organic crop production

Alternating between organic & non-organic

Are there any exceptions to the rule against alternating between organic and non-organic production outlined in 5.1.7? (6)
The intent of 5.1.7 is to prevent deliberate abuse. CBs may be faced with situations that appear to fall in this definition; but, that do not demonstrate a deliberate abuse of alternating production. In these cases, the CB should note that although the organic certification lapsed for a period of time, the operator has not intentionally violated 5.1.7. These cases could include instances where the loss of certification where the cause was beyond the operator control (e.g. mandated use of a prohibited substance, natural disaster, financial failure of the enterprise) or is unconnected to the management or operational decision-making connected to the organic operation (death of a family member, marital distress, inter-generational transfer).

What is required for a certified farm to retain the possibility of future certification beyond an intervening period when no certification is required for the sale of product? (97)
In the event that the operator has no crops to sell, and wishes to allow certification to lapse, but desires to retain the possibility of certifying again in the future, it would be necessary to maintain records documenting compliance with the standard. The application to re-certify would have to be done in compliance with requirements of the Organic Products Regulations as they apply to new operations. 5.1.7 refers to alternating between the use of organic and non-organic production methods, which implies the use of prohibited substance.


Owning organic and non-organic operations

If an operator owns two land-based operations, where one is organic and the other conventional, does the non-organic operation have to transition to organic as outlined in 5.1.3 and 5.1.4? (488) (June 29 2020)
If the non-organic operation is a separate legal entity, then it is not subject to organic transition certification requirements in 5.1.3 and 5.1.4. But if the non-organic operation is not a separate legal entity 5.1.3 & 5.1.4 are applicable and the operation is subject to the purview of the CB. (See 'legal entity' description in C.2.4.4 in the COR Operating Manual).



How should the minimum buffer zone be measured in an orchard? (138.1)
The distance is measured from drip line to drip line between an organic orchard and adjacent non-organic block. If a portion of some of the trees is within the 8 meters, the entire harvest from those trees is sold as non-organic. As tree canopies expand with time such buffer areas need to be checked annually to reaffirm compliance.

Could a buffer zone larger than 8 m. be required in special circumstances, for example when prohibited substances are being applied on the windward side of the organic crop? (138.2)
Yes. 5.2.2 states that ""distinct buffer zones or other features sufficient to prevent contamination are required"". If there is a risk of contamination, an 8m or wider buffer (5.2.2 a)) or other effective barriers (5.2.2 b)) must be employed. For isolation distances relevant to GE crops, refer to 5.2.2 d). " 

Does the crop in a buffer zone need to be visually distinguishable from the organic crop? (272)
No. The same crop can be planted in the buffer zone as long as the buffer crop is harvested and directed out of the organic stream, and such activity is documented.


Parallel production – Seedlings

Is it parallel production if the same seedling type production is separated by time? (57)
The growing of visually indistinguishable crops (organic and non-organic) non-simultaneously does not constitute parallel production. This rule applies equally to all field crops and greenhouse production, including seedlings.


Parallel production

Can parallel production be allowed if management to avoid co-mingling is documented? (1)

5.1.4 prohibits parallel production of most non distinguishable crops by the same enterprise. Some exemptions do exist (e.g. perennial crops (already planted), agricultural research facilities, and production of seed, vegetative propagating materials and transplants) with conditions. Refer to 5.1.5 for further details.  Post harvest operations are not subject to this prohibition.


Is the word 'simultaneous' in 3.46 defining “parallel production” applicable to:

1) geography? - For example, a farm in isolated from other farm sites owned and operated by the same organic operation)? 

The requirement is that the same or similar crops grown conventionally and organically within an operation are visually distinguishable by a common person, regardless of location,

2) crop rotations? For example,  where an operation has two production units(one organic and the other not), can a non-organic crop be grown in Field 1 (always conventional) in Year A and then the same crop  grown in Field 2 (always organic) in Year B when Field 1has a different crop? (450.1) - 26 Sep 2019

In the example given this same crop would be planted in different years, therefore the growing of that crop would be considered neither simultaneous nor parallel.

5.1.4 states that parallel production is an exception to an enterprise’s entire conversion to organic. “Operation” is defined at 3.41 and may have multiple production units but “enterprise” is not defined in the Standards. What is the difference between enterprise and operation? (450.2) - 26 Sep 2019
Enterprise and operation are synonymous. It is anticipated that this will be clarified in the 2020 standards revision.

Does the term “farm, company or organization” included within 3.41 definition of an operation encompass separate and distinct divisions of one overall food conglomerate, each division having a separate business name, management and geographical location for crop production? (450.3) - 26 Sep 2019
If each division is a legal entity they need to be certified individually. If the food conglomerate is the certified entity then regardless of its divisions having separate names, any parallel production of a crop within the conglomerate (even if the production took place at different divisions) would be prohibited. (See 'legal entity' description in C.2.4.4 in the COR Operating Manual)


Parallel production – Seeds

Can seeds be considered an input as opposed to a crop, for the purpose of allowing seed companies to practice parallel production? (2)
Seed companies can practice parallel production. Refer to 5.1.4.


Parallel production & hydroponics

Can an operator engage in hydroponic production (not organic) and produce the same products using organic methods? (261)
5.1.4 does not allow parallel production for greenhouse annual crops. The production of visually indistinguishable products is not allowed, regardless of the non-organic method of production.


Transition – Management change

In the case where there is a change in management is a 12 month transition period necessary? (58)
A change in management or control of an organic operation does not necessitate a 12 month transition period. It is a new operation that requires a minimum of 12 months of supervision by a CB, not a new operator.

Transition – Adding new fields

Does the requirement, in 5.1.1, that land be in compliance with the standard for 12 months prior to harvest apply to new fields added to an existing application? (8)
If it can be verified that no prohibited substances have been applied for the past 36 months, no transition period for new fields for existing operators is required. (Reference, 5.1.2)


Transition of a GE crop field

When calculating the 36-month transition period, does it begin on the date that a prohibited GE crop was last sown? Or last harvested? (459.1) - 21 June 2019 - confirmed 18 August 2020
The 36-month transition period is calculated from the date on which a prohibited GE crop was destroyed (e.g. harvested, tilled, ploughed).


Oversight of the CB during transition

During the transition period, does an operator need to consult with their CB before applying any crop amendments? (459.2)  - 21 June 2019
Detailed input records must be kept during the 36-month transition period so that compliance can be verified by the certification body. The standards require a certification body's oversight during the last 12 months of transition, not the full 36 months.


Type of plant grown in containers

Can any type of plant, including perennials, be grown in containers or any off-the-ground structure (e.g. elevated gutters) and be compliant? (396)
Yes. Plants, including perennials, can be grown in containers or any off-the-ground structure in a greenhouse or outside if the growing media substrate meets the requirements of 7.5.2 and the soil definition (3.62 in 32.310). Keep in mind that if the crop is typically trellised / staked - the production system must also comply with the requirements of 7.5.5 of 32.310.


Non-organic trees or grapevines planted before end of transition

If non-organic trees or grapevines are planted before the land has completed the 36 month transition, how long before the fruit would qualify as “organic”? (431) - 19 Apr 2019
The fruit would qualify as organic either after the completion of the 36-month transition period (5.1.1), or 12 months after the planting date (5.3 b) – whichever is later. For example, there is 4 months left in a land transition and the producer plants non-organic planting stock. The fruit could not be harvested as organic until 8 months after the land meets the 36 month transition requirement.


5.2 Environmental factors

Isolation distances

How should the note in 5.2.2 on isolation distances for preventing GE contamination be used in the enforcement of 5.2.2 d)? (282)
Isolation distances are one of many strategies that could be used to minimize contamination risk. Shorter distances other than those provided in the 5.2.2 Note may prove to be as effective depending on wind direction, topography, vegetation etc. Other mitigation strategies such as delayed planting, border rows, etc., could also be effective on their own, or in combination with other tactics. It is critical to understand that Notes and examples in the standard are not themselves enforceable, and are used to give insight or direction on how to implement the standard.

Note 5.5.2 d)

Does the note in 5.2.2 d), “(for seed production)”, refer to the organic alfalfa or to the GE alfalfa? (282.2)

Organic alfalfa seed fields should be 3km from ALL GE alfalfa fields (i.e. both GE seed production fields and GE hay fields).


Corn field is surrounded by GE corn

My sweet corn field is surrounded by GE corn. Since I do multiple plantings, I know that there are times when pollen from the GE corn contaminates my crop, but I have nowhere to locate the corn where this will not be the case. Can this crop still be compliant in light of the new GE risk management criteria in 4.4.4 and 5.2.2 d)? (296)
The product of farms whose operators engage consistently in implementing mitigation strategies aimed at eliminating risks of GE pollen contamination will be considered compliant.

Contamination – Accidental

What are the effects regarding certification, of an unintentional spill of plastic pellets onto an organic field? (67)
The standard requires 36 months transition after the application of a prohibited substance by the operator (5.1.1 - 32.310). Depending on the nature and extent of contamination, buffer strips around the contaminated zone and/or a transition period may be reasonable ways of maintaining the organic integrity (refer to 5.2.2). A prescriptive solution that applies universally to all cases of potential contamination is not possible, but in every case the degree of risk must be assessed and every attempt must be made to mitigate the negative impact on the final product. (See Introduction III- Organic practices paragraph 5).

GE seeds in an organic field

If GE (untreated, treated) seeds are accidentally dumped in an organic field, would that field require a 36-month transition to regain compliance? (313.1)
No - if the seeds are untreated. However, the pile of untreated seeds has to be removed as soon as the accident is discovered. If the seeds are treated, the area where the dumping occurred must go through a 36-month transition and a 8 metre buffer around the area would be required as well (5.2.2).

If GE seeds are accidentally planted in an organic system, is a 36 month transition required? (313.2)
Yes. Prohibited substances / products (see definition 3.57) references 1.4, therefore fields contaminated with products of genetic engineering require a 36 month transition to return to organic status. Any plants that have sprouted from these GE seeds have to be destroyed prior to seed set as soon as the accidental planting is noted. The 36-month transition, in this circumstance, will be calculated from the point in time at which the GE plants have been destroyed (e.g. tilled, mowed).

If GE seeds were purposefully planted in an organic system, would the 36-month transitional period be required after removal of the plants? (313.3)
No. Transition periods are irrelevant under this operation's management. Because alternating in and out of organic production methods is prohibited (see 5.1.7 of 32.310), the certification would be cancelled for current and future crops grown on that production unit.


Emergency pest or disease treatment

In the case of contamination with a prohibited substance used in a government sponsored pest control program, what are the implications for organic operators regarding suspension of certification? (69)
The standard requires 36 months transition after the application of a prohibited substance by the operator (5.1.1 - 32.310). Depending on the nature and extent of contamination, buffer strips around the contaminated zone and/or a transition period may be reasonable ways of maintaining the organic integrity (refer to 5.2.2). A prescriptive solution that applies universally to all cases of potential contamination is not possible, but in every case the degree of risk must be assessed and every attempt must be made to mitigate the negative impact on the final product. (See Introduction III- Organic practices paragraph 5)

Equipment – Lubricants

Are the lubricants used in harvesting equipment regulated by the Standard? (122)
There is no specific reference to the maintenance materials such as lubricants in the standard. But contamination of land with such substances would fall under 5.2.1 of CAN/CGSB 32.310 ‘Environmental factors’ which states "Measures shall be taken to minimize the physical movement of prohibited substances onto organic land and crops from - equipment used for both organic and non-organic crops.” Thus equipment must be well maintained to minimize potential contamination.

Equipment – Shared

Are there any guidelines for cleaning farm equipment that is shared with non-organic operators? Could the sharing of equipment jeopardize certification? (147)
5.2.1 states "Measures shall be taken to minimize the movement of prohibited substances onto organic farmland and crops from adjacent areas". Where there is a risk that shared equipment could convey prohibited substances, seed, or crop, it must be adequately cleaned to ensure that contamination of organic product is prevented. The operator must document the cleaning process.

Irrigation – Shared

Can a farmer irrigate land from an irrigation system that uses Magnicide, an aquatic weed herbicide? (19) (104)
Active substances included in Magnicide are not allowed for application to organic production units. If the irrigation system can be shown to be free of residues from prohibited substances such as Magnicide, it may be used to irrigate organic farms. (see 5.7 in 32.310)

Treated posts

Would dipping untreated wooden posts in paraffin wax or using a polyethylene sleeve be allowed under 5.2.3? (186) 

Yes. Paraffin or polyethylene coverings can be used.The prohibition of wood treatments in 5.2.3 was aimed at eliminating toxins commonly used to prolong the life of wooden posts.


Is the buffer zone around treated posts permanent or transitional? (12.1)
The standard does not prescribe any buffer zone surrounding treated fence posts. The only time a buffer zone may be necessary is when a neighbour installs treated posts adjacent to your cropping zone. The status and width of the buffer in these circumstances will be determined on a case by case basis.

What happens when an applicant installs treated posts? (12.2)
If a commercial availability search was not done, a 36 month transition period dating from the installation of the treated posts applies to the specific production unit (e.g. field(s)) where the posts were installed.

What happens when an existing organic operation installs treated posts? (12.3)

This could lead to decertification if proper commercial availability due diligence (5.2.3a) cannot be demonstrated.


Is copper sulphate allowed as a treatment for fence-posts on pasture? (9)
No. Copper sulphate is not listed as treatment for wood product; however both copper hydroxide and borate are allowed in table 4.3 of PSL. For new installations or replacement purposes, metal, plastic, concrete, or protective sleeves should be used as alternatives for fence posts. For further information consult 5.2.3 (32.310)

Treated fence posts in livestock production

Do the treated wood restrictions in 5.2.3 a (32.310) apply to barns, corrals and handling facilities? (314)
Yes. As livestock production is a land-related activity (6.1.3) the treated wood restrictions in 5.2.3 a) applies to both organic crop and livestock production units including livestock facilities.


Certification of plantations

If culinary oils are harvested from an on-farm tree plantation, aka blocks of trees planted on a farm for this specific purpose, should these oils be certified under 'Crop production' (clause 5) or 'Wild crops' (clause 7.6) of the Canada Organic Standards? If the same culinary oils are harvested from private wood lots, or from Crown land timber which clause in the standards is applicable? (341)
The 'Crop production' requirements in the standard are applicable for the on-farm tree plantation scenario while the 'Wild crops' requirements are applicable for the wood lot and crown land situation. 'Wild crop' is defined in 3.71 of the standard as "plants collected or harvested in their natural habitat."


5.3 Seeds and planting stock

Perennials – Transitioning

If perennial planting stock not treated with prohibited pesticides is planted on an organic farm, can the harvest be considered organic in the first year? (200)
No. Not within the first year. The fruit from non-organic perennial planting stock will only be compliant following 1 year (12 months) of organic management (CAN/CGSB 32.310 5.3 b).


Seed – Buffers

Are seeds produced on buffer strips able to be planted in organic fields? (17.1)
Seeds grown on buffer strips under the Standards are the same as those grown on conventional farms (see 5.2.2 c)). Exceptions to the use of organic seeds are specified in section 5.3 a).

Seed – Common

Can non-organic common seed be used if organic common seed is not available? (17.2)
Yes. For the purposes of 5.3 a),  "common" could be considered a varietal distinction subject to the exceptions to the use of organic seeds. See 3.13, definition of "commercially available."

Seeds for green manure crops

Are the seeds used to grow green manure crops, intended for incorporation into the soil, required to be organic? (269)
Yes. All seeds used in the organic production system, whether the plant is used for food, feed or soil incorporation have the same requirements outlined in 5.3 - Seeds and planting stock. They must be organic except under the specific exceptions listed.


Seeds – GMOs

What level of GE contamination would be acceptable in seeds used for production under organic standards? Is it the responsibility of the operator or of the seed trader to check the GE contamination of the seeds sold for organic production? (41)
1.4 a) prohibits the use of all materials produced through genetic engineering. Where there is a risk of GE contamination, the operator is responsible to document (4.4) all potential sources, and the management strategies employed to minimze the risk of contamination (5.2.2 d)) Testing is not mandatory but could be used as a monitoring tool by the operator. Certification Bodies also have the discretion to test when fraud or contamination is suspected.


Use of non-organic planting stock

When using non-organic planting stock (such as plant tissue/cuttings) due to the fact that the organic form it is not commercially available (as permitted under 32.310 Section 5.3), at what stage would the resulting plant or transplant considered to be organic and be able to be sold as such? (475) (February 17, 2020)
A cutting is not considered organic until one year (perennial) or one crop season (annual) under organic management.


Seed – Transitional fields

Does the requirement to use organic seed, tubers etc. (5.3) preclude the use of seed grown on transitional land within the same operation? (113)
Seed grown on transitional land is acceptable as it meets the requirement of 5.3 and as it has not been grown using prohibited substances ot techniques. 


Use of GE seeds before transition

Can prohibited substances, including GE seeds, be used by an operator in fields not yet in the 36 months transition period? (468) - December 2, 2019
Yes. Prohibited substances can be used prior to the start of the 36-month transition period providing the crop is not parallel production with organic crop on the operation. Take note that in the case of GE crops, calculation of transition period begins after harvest and /or destruction of the crop per SIC Q&A 459a.


Seed – Treatments

About untreated seeds:
a) What is the definition of “untreated seed” as it applies to 5.3 (32.310)?

Untreated seed is seed to which no pest control products, plant growth regulators, inoculants, or fertilizers, pelletizing agents, coatings, priming substances etc., have been added. 
Pelleting of organic and non-organic seeds is allowed, but in both cases the pelleting substance must comply with restrictions in table 4.2 and 4.3. Priming of non-organic seeds is allowed if solely for the purposes of improving speed and uniformity of germination by getting water into the seed. Treatment of organic and non-organic seed, with substances on 4.2 and 4.3 is allowed.

b) Can bleach be used on seeds? (77)
No, bleach cannot be used on organic seeds to either clean or treat them. Chlorine can be used on non-organic seeds only between harvest and storage. Once non-organic seed is purchased by an organic operation, it must be handled the same as organic seed. 


Organic percentage for seeds

Do seed coatings or treatments need to be considered when calculating the organic percentage of an organic seed product? (472) - December 2, 2019
No. Seed does not fall under Clause 9, therefore a calculation of percentage of organic ingredients is not applicable. The seed needs to be organic and any coating or treatment must be listed in PSL 4.2, 4.3.


Tissue culture

Are propagules produced through plant tissue culture micropropagation included within the provisions of 5.3 (32.310) requiring that they be produced in accordance with the standard? (203)
Yes. 5.3 applies to propagules produced through plant tissue culture micropropagation.

Offspring of GM seeds/plants

Can the offspring of GE seeds/plants be organic? (256)
No. The use of GE plants or seeds is prohibited.


5.4 Soil fertility and crop nutrient management

Crop rotation

Does the definition of crop rotation (3.17) mean that growing the same crop 2 years in a row is inadmissible? (134)
While the standard states that crop rotation shall be as varied as possible, growing the same annual crop two years in a row is not prohibited. 5.4.1 and 5.4.2 require that a soil fertility and crop nutrient management program be maintained. A regular soil monitoring program can be used as evidence of "practices that maintain or increase humus levels that promote an optimum balance and supply of nutrients, and that stimulate biological activity within the soil". 


Rotation with crops not under COR

Can an operator use crops not covered under the Canada Organic Regime (COR) (tobacco or cannabis) as part of the operation’s rotation and still keep the organic status of the fields? (466) -December 2, 2019
Yes. Crops that are not covered by the scope of the COR may be grown in a rotation without affecting the organic status of the field(s), provided that they are managed in accordance with the standard.



Is the prohibition on hydroponics applicable only to greenhouses, or to all types of crop production? (74.2)
The prohibition of hydroponics is universal and not limited to greenhouses. See 5.4 (soil fertility requirements) and 7.5.3 (hydroponic prohibition).

5.5 Manure management

Manure sources

Can manure from livestock raised in cages be used, if the farm has a nutritional deficit and no other manure is available within a reasonable distance? (83)
As per 5.1.1 a), only manure from caged animals that cannot turn 360°is prohibited (e.g. manure from sows in farrowing crates). There are no exceptions.

Is the manure from a conventional farrowing operation compliant with the standard? (90)
Manure from sows that are kept in traditional farrowing crates and not able to turn around is prohibited under 5.5.1 a). This is the intent of the standard. The wording of 5.5.1 a) leads to the need for interpretation of the term 'fully caged system'. The part of the operation where traditional farrowing crates are used constitutes a 'fully caged system' under the standard and manure from those animals is prohibited, notwithstanding the fact that some other animals in the barn are housed differently. If the manure from the sows in the traditional farrowing crates can be segregated, the rest of the manure will be acceptable.

Does the presence of animal droppings in fields, orchards and vineyards require a waiting period as prescribed in (31) (159) does not apply to incidental animal droppings such as those from wild animals or birds, grazing or working animals; however, (a) does apply and requires diligence on the part of the operator to ensure that any activities under his/her control do not cause pathogenic microbial contamination of the crop. clearly states if livestock are part of the cropping or pest control program there has to be a management plan in place regarding manure related contamination and the eatable crop.


Manure from nonorganic animals raised on an organic operation

5.5.1 states "Animal manure produced on the operation shall be used first." If the operation raises non-organic animals, should this manure be used first before the operation attempts to source organic animal manure from off-farm? (438) - 21 June 2019
Yes. Animal manure, whether from organic animals or not, produced on-farm shall be used first. On-farm nutrient cycling is an important principle of organic production. The organic matter produced on the operation shall be the basis of the nutrient cycling program. There is confusion on this issue between the English and French versions of the standard which this also seeks to address


Manure from confined operations

Can manure from confined animals feeding operations where 5.5.1 and 5.5.2 have been met be applied on organic land even if it contains prohibited substances? (322)
Yes. Manure can be used directly as long as it follows 5.5.1 and 5.5.2.



6  Livestock production


6.1 General

Outdoor pastures and outdoor areas

What is the difference between outdoor pastures and outdoor areas? (458.1) (February 17, 2020)

“Outdoor pastures” provide vegetation and nutrition to animals and are required during the grazing season (see 32.310 6.1.3 a) for the purpose of feeding livestock. ”Outdoor areas” may or may not contain vegetation. Outdoor areas are used to accommodate livestock health and allow for natural behaviors throughout the year when the animals are not on pasture (see 32.310, 6.7.1 a)).


Poultry peepers/blinders

Are poultry Peepers/Blinders, with or without attachment pins allowed when used to prevent cannibalism? (350)
Poultry peepers / blinders are permitted only without pins and only when all other management methods have been attempted and failed. As required per 6.1.6 documentation must be maintained to demonstrate strategies are in place for the reduction of blinder use.


6.2 Origin of livestock

Breeding stock – Alternating organic and non-organic management

Please clarify the meaning of  Does it allow that animals could be repeatedly fed conventionally until the last trimester of pregnancy, and still give birth to offspring compliant with the Standard? (87) applies only to herds and individual animals in transition. For animals already under organic management, the feeding of non-organic feed at any time during gestation would render the mother and offspring non-compliant. Beef cattle and dairy breeding herds cannot be rotated in and out of organic production. Refer to 6.2.5.

Breeding stock

Can non-organic animals transitioned to organic management become acceptable a) for breeding? b) for slaughter? (48.1, 48.2)
Breeding animals may be transitioned from conventional to organic management for use in organic production according to the terms specified in the standard. (see 6.2.2, 6.2.3, and 6.2.4). A non-organic animal will never comply with the standard for the purpose of slaughter and use as organic meat. Breeding males used on organic farms do not have to be organic. 1.4.still applies.

Definition of dairy animal

What is the definition of “dairy animal” under the standard? (24.2)
A dairy animal is any animal in a herd that produces milk for human consumption.

Sexed semen

Can sexed semen be used in organic production? (40)
Yes, the use of sexed semen does not violate the standard (refer to 6.2.2 a).

Embryo transfer

Is embryo transfer (the collection of eggs from one female and subsequent implantation in another animal to complete gestation) allowed? (240) 

No. In 6.2.2 b), the standard prohibits embryo transfer techniques in organic livestock.


Can an animal which is the product of embryo transfer be brought into organic production? (214)

Yes, with the understanding the animal cannot be sold for slaughter, only used for breeding or dairy, subject to the transition requirements of 6.2.4 and 6.3.


Fertilized eggs

Can birds hatched from eggs treated with antibiotics be certified organic? (271)
No. states "neither day-old chicks nor the fertilized eggs they hatched from shall be given medication other than vaccines".
Note: in the 2006 version of 32.310, poultry used for edible products had to be under continuous management beginning no later than the second day of life. This meant that the treatment of eggs was not the responsibility of the operator. That clause has been revised and operators have one year from the November 25, 2015 date of publication to comply.

Health care for poultry

Is it correct to interpret clause as indicating that day-old birds and/or fertilized eggs can ONLY be given vaccines, while day two and older can be given vaccines and/or other medication, if required? (339)
Yes, fertilized eggs and day old birds may only be vaccinated, while medications used for older birds are restricted to the constraints in 6.2, 6.6.10, 6.6.11 and 6.6.12 (32.310).


Raising pullets for layer organic operations

May non-organic operations raise pullets for organic layer operations? (428) - 19 Apr 2019
No. Pullets must be produced by operations holding valid product certificates (32.310 1.1 a "...livestock..."). Even if the sub-contracted operation is inspected annually by the certifier of the layer operation for whom the pullets are being raised, and the pullets are under "continuous organic management" from the second day of life ( a)), this does not meet the requirements of the scope of the standard.


Transitioning of dairy calves

Can a dairy calf which is part of an organic operation be fed conventional milk, then transitioned back to organic status? (see (259)

No. applies only to herds and individual animals in transition.


Breeding sows – Synchronized estrus

If a producer purchases non-organic non-gestating sows for breeding, brings them into a new operation site, then uses hormones to trigger and synchronize estrus, would the piglets born from these sows on this site be considered «organic» if these females have been under continuous organic management from the beginning of the last third of their gestation period? (195)
While the standard allows for the introduction of non-organic breeding stock into an organic operation, it requires that from the moment of introduction, the operator complies with all the rules for organic livestock husbandry. The use of hormones to trigger estrus is specifically prohibited in 6.2.2 c), therefore the use of this technique would be a serious non-compliance.


Is the use of cloned animals allowed? (148)
No. All of the conditions listed in 1.4 are forbidden. The origin or lineage of animals (1.4 h)) needs to be known to ensure that no cloned animals are used.


6.3 Transition of livestock production units to organic production

Pasture – Poultry

Does 6.3.3 apply to pasture used for poultry? In other words can the raising of pullets be timed to coincide with the transition of land rather than waiting until the pasture is CO to start a new flock? (99)

6.3.3 applies to pasture used by a herd or a flock of sheep and not to pasture used for poultry. Pasture for poultry must be free of prohibited substances for 36 months prior to use (6.13.1 c). In other words, land can be in transition still when pullets are started, but the land must have completed the necessary transition period and been granted organic status by the time birds are ready to go out to pasture. Pasture is considered an organic crop and operators making their initial application must be in full compliance with the Standard for at least 12 months before it can be used by organic poultry (5.1.1).

Transition - Outdoor runs

Does the requirement for a 36-month transition of land for crop production apply to the outdoor runs required to permit poultry access to the outdoors? (225)
Yes. Poultry eat when they go outside, even ingesting small amounts of soil. Since organic feed is required (6.4), all outdoor runs/pasture must have completed the necessary transition period and been granted organic status before being accessed by organic poultry.


Offspring born under transition

Can livestock offspring be considered organic for meat, if they are born on a production unit in transition, prior to the end of the final 12 months of transition, as long as the dam has been under organic management for the last third of gestation ( b), including eating pasture and feed produced within the operation, which is considered organic when consumed by the transitioning herd or flock on the same production unit, as per 6.3.3? (409) (29 avril 2020)

No. With reference to subclauses and 6.3.3, livestock offspring born on land in transition would not be considered organic for meat. 6.3.3 allows for the final third of gestation to occur during the final months of transition, so that offspring born on or after the day that the land has completed the necessary transition period and been granted organic status can be considered organic for meat.


Transitional feed

When a beef cow herd is being transitioned to organic, does 6.3.3 give permission to use the transitional feed being produced on the farm, to feed gestating animals whose offspring will be eligible for sale as organic? (179)
Yes. Provided that the timing of the completion of the transition of the land on which the feed has been grown coincides with or precedes the birth of the organic offspring

Feed from transitional land

Can the use of feed from transitional land allowed in 6.3.3 be extended to apply after the transition of the livestock is complete? (257)
Feed produced on land in the final year of transition (commonly referred to as T-3 feed), is considered as organic within the farm unit while the herd or flock of sheep is in transition. The T- 3 feed produced and harvested before herd transition is complete may continue to be used as organic within the farm after herd transition is completed. T-3 feed harvested after herd transition is complete has no organic status even within the farm.


Non-organic feed when transitioning entire dairy herds

Is GE feed permitted in the 20% non-organic feed allowance for first time transitioning entire dairy herds (6.3.1 a)? (407)
Yes. GE feed may be used in the 20% non-organic feed allowance when initially transitioning an entire dairy herd, and this information should be documented in the operation's organic plan.


Parallel production in livestock production

Is parallel production in livestock prohibited?  If so under what circumstances might it be allowed? (283)

Within the same production unit (definition 3.56) parallel livestock production is prohibited. This can be discerned by referring to the parallel production definition (3.46) that includes livestock; and 6.7.5 which stipulates all animals in a production unit must be managed organically whether or not all the animals have organic status. The non-organic animals must be clearly identified.
An exception exists when there is more than one production unit in an operation and complete separation is ensured. This would require separate records, barns, separate feed and input storage areas, separate runs, and separate pasture, etc.


6.4 Livestock feed

Buffers – Livestock feed

Can livestock feed harvested from the buffer zones around organic cropland be fed to livestock in transition to organic? (149)
As per 5.2.2 c), feed harvested from the buffer zones is non-organic. Feeding buffer zone feed would be the same as feeding conventional feed.


Treatment of stored feed

Can stored livestock feed (6.4.4) be treated with PSL 4.3 and 5.2 listed substances? (330)

Substances listed in 5.2 can be applied to or combined with stored livestock feed (6.4.4). Substances listed in Tables 8.2 and 8.3 may be used if their substance listing annotation does not prohibit direct contact with organic products. Substances in 4.3 can only be used during crop production - not post-harvest.


Feed storage – Commingling

A producer is feeding all his organic livestock feeds to non-organic livestock.   During storage they may be comingled with non-organic feeds purchased from off the farm. Is there any risk that by doing this the producer would compromise the ability to certify future crops from the same fields? (97.1)
No. At the point in time where separation between organic and non-organic feed is compromised, the feedstuff in question loses organic status. This has no effect on the organic integrity of the field and the capability to produce organic feed in subsequent years. If feeding occurs on the field it must be non GE feed. 


Emergency feed

Can the allowance of non-organic feed in catastrophic circumstances (6.4.7 a)) be expanded to include commercial or logistical challenges outside the operator's control? (e.g. a shipment is held up by border inspection) (156)

No. The examples of farm scale catastrophic events cited in 6.4.7 a) (fire, flood, extreme climatic conditions) do not extend to commercial or logistical problems.

Is the operator required to obtain pre-approval for use of non-organic feed during a catastrophic event? (89.1)
No, the operator does not need pre-approval. However, the operator should notify their CB and explain the situation as soon as possible. It is the responsibility of the operator to adequately and successfully demonstrate to the CB that 6.4.7 a) is applicable and the instructions laid out there have been met. 


Can you give some guidelines around the use of the 10 day maximum in 6.4.7 a)? (89.2)

Ten consecutive days from any catastrophic event, is the maximum permitted given the intent of 6.4.7a which was to allow the operator time to source organic feed.


6.4.7 b) allows for the feeding of non-organic forage to breeding herds in the case of a regional forage shortage. If a producer anticipates running out of organic forage: (157)
a) Can they prepare by sourcing the non-organic feed before they run out?

Yes. The operator may source the non-organic forage ahead of time, but before feeding, the regional feed shortage must be confirmed by the CB. Also all other conditions of 6.4.7 b)  must be addressed including: maintenance of detailed records to track feed and animals fed, to confirm non-GE status of the feed. Animal must be segregated and effort should be taken to use transition feed or at least forage grown without prohibited substances.. 

b) Which animals can be fed the non-organic feed and what are the implications for the status of meat and milk?
With the agreement of the CB, the non-organic forage may be fed to: 1) non-lactating dairy animals - without affecting their status in future lactation. 2) beef cows or ewes that are not nursing offspring, during the first 2 trimesters, without affecting the status of future offspring in utero.


Bypass fat

If the conditions outlined in 6.4.7, which allow for temporary use of non-organic feed are met, would this allowance also extend to the use of non-organic bypass fat? (95)

No, as the feed energy needed could be sufficiently provided by  non-organic grains, silage and haylage after the catastrophic event. The allowance to use non-organic feeds is intended to allow the operator to maintain the health of animals following a farm catastrophe.


Use of non-organic feed

Under what circumstances can a dairy operation use non organic feed? (260)
1. Catastrophic event: Following a catastrophic event that directly affects the operation, a dairy herd may be provided non-organic feed for a maximum of ten consecutive days, as specified in 6.4.7 a. In this case there is no interruption of the production of organic milk and all animals retain organic status for sale as meat.

2. During a regional organic shortage, lactating animals must be provided a 100% organic ration for their milk to retain its organic status. In other words, milk from dairy cows provided non-organic forage as a result of a regional organic feed shortage loses its organic status. For milk from these cows to regain organic status: a) these cows must have been provided a minimum of 80% organic feed during the regional organic forage shortage; and b) a three-month transition period in which these cows have been fed 100% organic feed must be completed.

3. Dairy herds in transition to organic production may be provided non-organic feed, in accordance with the rules in 6.3.1 a and b, which allow cows to be fed for 9 months with a minimum of 80% organic feed ration, followed by 3 months of 100% organic feed. Transitional feed in the last year of transition, produced on a farm transitioning its whole dairy herd to organic production may be considered to be organic on the same farm. (32.310-6.3.3)


Milk to replacement kids

Can non-organic reconstituted milk be given to the replacement kids in an organic goat dairy herd if the 12 month transition for the kids is respected? (394)
No. The exception for 6.2.3 only applies to herds and animals in transition to organic production. 6.4.3 d) provides specific requirement for lambs and kids which only permits organic milk (fresh whole or reconstituted). 6.4.7 only permits non-organic feed in the case of a catastrophic event or a regional shortage for breeding herds. 6.4.7b also specifies that 6.2.3 applies to offspring.


Feed – Transitional

When a beef cow herd is being transitioned to organic, does 6.3.3 give permission to use the transitional feed being produced on the farm, to feed gestating animals whose offspring will be eligible for sale as organic? (179)
Yes. Provided that the timing of the completion of the transition of the land on which the feed has been grown coincides with or precedes the birth of the organic offspring.

Silage inoculant additives – Colour

If a silage inoculant contains synthetic colouring agents, does that mean that it is prohibited for use in organic livestock feed production? (94)
Yes. The use of synthetic colouring agents (6.4.4 j)) makes the product non compliant for use in organic feed.

Summer ration – Long-fibre forage

When calculating compliance with 6.4.3 g) & h) of a summer ration for ruminants, can pasture be considered “long-fibre forage”? (194)
No. 6.4.3 g) & h) address feed rations when animals are not on pasture. During the grazing season 6.1.3 a) applies, and requires that sexually mature ruminants obtain a minimum of 30% of their total forage intake from grazing calculated on dry matter basis.

40% grain ration in early lactation

6.4.3 g) allows for increased grain feeding during uncommonly cold conditions or when forage quality is compromised to ensure that nutritional requirements of ruminants are met. Can dairy cows be fed more than 40% grain in early lactation when their energy requirements are highest? (295)
No, dairy cows cannot be fed more than 40% grain to meet their nutritional needs in early lactation. The allowance for feeding more grain in 6.4.3 g) is in exceptional circumstances beyond the control of the operator.


Percentage of organic ingredients for feed

May livestock be fed organic food waste containing 95% or more organic ingredients? What about food waste stemming from products only containing 70-95% organic ingredients? (372) - 19 Apr 2019
Livestock may be fed organic food waste (≥ 95% organic content) certified in accordance with 32.310 subclause 9.2.1. Food products containing 70-95% organic ingredients and compliant with 32.310 subclause 9.2.2 can only be fed to livestock according to the derogation in 6.4.7. The subject of this Q&A is under review by the 2020 CGSB Technical Committee.


Vegetable matter

Regarding the 'vegetable matter' element in requirement for poultry and pork (6.4.3 j) (340) (June 29 2020)

a) is organic vegetable matter required?

Yes. Organic vegetable matter is required.

b) would non-cereal grains (soybean, flax, corn) count as vegetable matter?

No. Vegetable matter is referring to fruit (apples, pears etc.) and vegetables (lettuce, potatoes, squash, etc.) and the associated crop waste and forage (straw, hay).

c) would straw and seed cleanings count?

Yes - for straw. No - for grain based seed cleanings.

d) would a grassed access area count?

Yes. Organic pasture would qualify as vegetable matter.

e) would alfalfa meal or pellets count?

Yes. Alfalfa in any format satisfies the current requirements.

This vegetable matter fraction can be supplemental to the feed ration or can be included in the feed ration


6.5 Transport and handling

References for animal transportation

Clause 6.5 refers to the Code of Practice for Care and Handling of Farm Animals: Transportation. It also references in a note the Health of Animals Regulations under the Health of Animal Act (CFIA). If these two sets of rules contradict one another, which one is to be referred to in evaluating compliance? (315.1)
These two references are not in contradiction. Table 4 of the Code of Practice for Care and Handling cites the Health of Animal Regulations. This table shows maximum times for travel. When these maximums are reached, it requires that the animals be unloaded and given feed, water and 5 hours of rest time.

If I have a choice between two slaughterhouses - one is 2 hrs away and another 6 hours. Am I at liberty to use the facility 6 hours away? (315.2)
No. 6.5.5 is explicit - “The duration of transportation shall be as short as possible." The Code of Practice care and handling recommendations become applicable when the closest facility is more than 5 hours away.


6.6 Livestock health care

Hormone treatments

Is the use of therapeutic hormonal treatment, for example prostaglandins to treat metritis, allowed in dairy animals?  If so, what are the restrictions and withdrawal times? (78.1)
For all treatments not listed on the PSL, a minimum withdrawal period of 14 days must be observed - see 6.6.10 d). Therapeutic use of hormones such a prostaglandin which is not listed on the PSL can be used when treatments listed in the PSL are unlikely to be effective, and preventive measures have failed. A 14 day withdrawal period must be observed. If prostaglandin is used in such a manner, as per 6.6.3, the animal is not eligible for use as organic meat, but this event is not counted as one of the dairy animal “treatments” referred to in 6.6.10 e 4) or 6.6.10 e 5), or 6.6.11 e). That 2 treatment restriction is only pertinent to antibiotics & parasiticides.

Can oxytocin be used to treat postpartum complications?  If so what are the withdrawal rules? (78.6)
Yes. 6.6.3 specifies that hormones are acceptable if the use is therapeutic, not preventive. For oxytocin, the animal does not lose status for use as organic meat. The withdrawal time is double what is stated on the label or 14 days, whichever is longer. (See PSL Table 5.3 Oxytocin and 6.6.10 d) - 32.310)

Medical treatments – Dairy animals

Do two separate incidents of treatment with antibiotics and paraciticides administered in combination count as one treatment, two treatments, or four? (135)
6.6.10 e 5)  and 6.6.11 e) mean that the maximum allowable is a total of two treatments per year including each incident of a combined treatment. For example when a combination of two drugs is supplied at the same time, they count as two treatments. Therefore two separate incidents of a combination dose would count as a total of four treatments.

In the case of antibiotic use in dairy cows, if the operator provides test results to show that there is no residue in the milk, can the compulsory 30 day withdrawal period be shortened? (125)
No. 6.6.10 e 2) states the minimum withdrawal of 30 days after the use of any antibiotics, even topical applications in milking cows. No exceptions are specified.

Medical treatments (parasiticides) – Slaughter animals

Please clarify the meaning of the standard regarding use of parasiticides in slaughter and milk as to the loss of organic status and withdrawal periods. (78.2) (24.1)

Parasiticides not listed in the PSL may be used on slaughter animals only if
• preventative measures have failed (6.6.11), 
• fecal samples confirm the correct diagnosis (6.6.11 a)),
• written instructions from a veterinarian which specify the product and method of parasite control (6.6.11 b)  have been obtained,
• the required withdrawal times is twice the label requirement or 14 days whichever is longer (6.6.11 c)),
• there can only be one treatment for slaughter animals under a year old and a maximum of two treatments in the life of the animal. (6.6.11 d),
• For dairy animals no more than a total of two treatments a year of antibiotics and, parasiticides in any combination. (6.6.11 e).  (refer to Q&A 135 for further insight on treatment counting).


Parasiticide treatment after 12 months

How many parasiticide treatments may be given to meat animals older than 12 months? (406)-19 Apr 2019

A meat animal can receive one parasiticide treatment within its first year. A total of two parasiticide treatments are permitted within a meat animal's lifespan (see 32.311 6.6.11 d).


Medical treatment – Withdrawal period

In the case of using a treatment not listed in 32.311, where no withdrawal time is indicated on the label, must organic operators still observe a withdrawal?  (78.4)
6.6.11 c) states that when drugs not listed on the PSL are used, a withdrawal period of 14 days or twice the label withdrawal shall be observed.  If there is no label withdrawal 14 days must still be observed.


Spray bandage

Is a spray bandage, sprayed on wounds, replacing traditional bandages, allowed? (292)
A spray bandage, containing ingredients not listed in 32.311, would fall into the category of "prescribed veterinary drugs" (6.6.10 c) and could be used if products permitted by the Standard "are ineffective in combatting illness or injury". Withdrawal period specified in 6.6.10 d) applies, as well as the special provision for poultry and breeding stock in 6.6.12.


Physical alterations – Anti-inflammatories

Are steroid anti-inflammatory drugs allowed during physical alterations? (78.3)
No – 6.6.4 c 2), by specifically noting “non-steroid” are permitted, implies that steroid anti-inflammatory drugs are prohibited for minimizing pain and stress during physical alteration.

Physical alterations – Beak trimming

What justification must be given in order for beak-trimming of day-old chicks to be compliant with the Standard? (275)
Since beak trimming is only effective if done before problematic behaviour starts the operator can point to previous experience or to the shared experience of operators to reasonably predict that problems would emerge to justify day-old beak trimming. The procedure for trimming must be minimal (6.6.4 c) and the operator must document the other measures taken to reduce or eliminate behavioural problems in flocks.

Can beak trimming be carried out as a preventive measure or is the allowance for this practice under 6.6.4 c) 4) only relevant after a problem arises? (101)
Yes, the practice of beak trimming is acceptable as a preventive measure to ensure the welfare of poultry if only a very small amount of the beak, the sharp hook, is trimmed or treated (6.6.4 b) 1). In order to remain compliant with the standard, the operator must also document the other measures taken to prevent or control problematic behaviours. Since the standard implies that this is an extraordinary event, it should not become the norm, and operators who employ this technique must review annually with the CB their plans to eliminate the need for beak trimming or treatment.


Physical alterations – Dehorning paste

Is de-horning paste allowed? (29)
Yes, all types of dehorning paste is acceptable under  6.6.4 a 4),  but operators must abide by applicable industry Codes of Practices (6.6.4 c).

Immunological castration - Pigs

Can immunological castration of pigs during the finishing phase be used to replace castration of young pigs? (218)
No. The substances used would have to be listed on 5.3 of the Permitted Substances Lists in order to be acceptable.

Livestock, vaccines – GE contamination

What would be the result of an unintended contamination of an organic livestock operation with a GM rabies vaccine? (52)
The note after 8.3.5 addresses the issue of emergency pest or disease treatment. The evaluation of compliance or non-compliance following this theoretical scenario would depend on: the degree of contamination; the precise nature of the contaminant; the ability of the operator to identify and exclude affected animals. How and why the contamination occurred is not relevant to evaluating compliance. Operators need to inform their certification body when such incidences occur.

GE vaccines

Can GE vaccines or vaccines grown on GE substrate be used in poultry if the conditions for the use of veterinary drugs (6.6.10) are met? (298)

Vaccines are categorized in the standard as 'veterinary biologics' not 'veterinary drugs'. GE vaccines that are products of genetic engineering, as defined in clause 3.27 of 32.310 cannot be used on two day old birds and older birds. Vaccines grown on GE substrate may be used if no alternative is commercially available and that no traces of the GE substrate exist in the vaccine (32.311 - 5.1.2). Day-old birds and fertilized eggs can be given any type of vaccine ( b).


GE vaccines for pigs

To prevent livestock losses to deadly diseases (e.g. CircoVirus in pigs), can a genetically engineered vaccine be used, if we consider that it is 'necessary to prevent or treat livestock health problems when other treatments permitted by this standard are not available." as stated in 32.310, 10.3 Criteria for Examination of Particular Substances, Table 9, under Livestock health care? (436) - 19 Apr 2019
No. At present the standard does not allow for the use of GE vaccines. Furthermore, clause 10 describes the process to be used when assessing additions or changes to the Permitted Substances Lists. Clause 10 is not a tool to justify the use of a specific input. The CGSB's Technical Committee on Organic Agriculture is discussing this issue during the current standards review.


Vaccines with preservatives

Are livestock vaccines containing bacteriostatic or fungistatic preservatives permitted? (402)
Yes. But do not overlook that 1) the vaccine cannot be the product of genetic engineering technology; 2) if there is residual substrate in the vaccines it is composed of listed substances, or address the commercial availability exception in 5.1.2 b) in the PSL for use of GE substrate when it's not included with the vaccine; and 3) in the case of poultry the vaccine is given before the chicks are 2 days old.


6.7 Livestock living conditions

Poultry housing – Sunlight

Does housing for broilers require windows for sunlight to enter while the birds are confined? (82)

Yes. As per 6.7.1 a) and 6.13.8, natural light inside the barn is required but windows are not necessarily the only mean to satisfy the standard. Light permeable fabrics are an alternative.       


Level of natural light in poultry barns

Can we have some guidance on how to evaluate the level of natural light in poultry barns? 6.13.8 requires the ability to read a newspaper but this reference is subjective and variable depending on the person's eyesight and the level of light outside. (316)
The enforceable norm for windows in poultry barns is stated in 6.13.8: "The total window area shall be no less than 1% of the total ground-floor area..." If a poultry barn's window area does not meet that minimum, 6.13.8 also offers an alternative means of demonstrating effective natural lighting: "unless it can be demonstrated that natural light levels are sufficient to read a document such as a newspaper anywhere in the barn." In other words, a newspaper that can be read outdoors using natural light must also be legible inside the barn


Composition of bedding

What materials can be used as livestock bedding? (318)

In addition to the materials described in 6.7.1 g, non-agricultural absorbent bedding sources (minerals, cellulose, sawdust, paper products, etc.) can be used for livestock bedding as long as they are not GE products (1.4 a), and do not contain and/or have not been treated with prohibited substances (1.4 l). The final clause in 6.7.1g is intended to address harvested plant material but is not intended to exclude other materials that meet the needs of the animal.


Bedding for poultry

Is an operator obligated to provide bedding for poultry (as in 6.7.1g), or is it enough to allow litter to “build up” from poultry waste without adding anything? (426) - 19 Apr 2019
Yes. Per 6.7.1g bedding must be provided from the onset of a cycle to "establish and maintain animal living conditions that accommodate the health and natural behaviour of animals". The bedding should be sufficient enough to maintain the animals clean, dry and comfortable. It should also permit the birds to express their "scratching" behavior. Note: 6.13.6 may mislead readers to think litter may be supplied, but the sentence should be read as "Bedding shall be provided and litter kept dry."


Outdoor access – Turkeys

If an operator arbitrarily confines turkeys for one week prior to slaughter, does this constitute non compliance with the standard? (39)
The standard sets out a number of legitimate reasons for denying outdoor access. Turkeys or other livestock cannot be denied outdoor access for any reason other than those outlined in 6.7.2. 

Outdoor access – Pigs

Can the organic operator choose to keep pigs confined, not allowing outdoor access, even when there is no risk to the animal caused by weather or stage of production? (196)
No. Complete confinement of pigs is non-compliant with 6.7.1 a). The standard sets out as the norm for animal husbandry, access to outdoors. It then states in 6.7.2 the specific exceptions to the rule which apply to all livestock. 6.15.2 outlines the outdoor exercise requirement for pigs.

Outdoor access – veterinarian recommendations

Under CAN/CGSB-32.310 Section 6.7.2, can operators limit access to the outdoors to their entire herd / flock (such as goats, sheep, cattle, poultry) for the entire winter if the operator provides a letter from their veterinarian stating that access to the outdoors is detrimental to the health of the particular species of livestock? (354)
No. The standards already provide sufficient flexibility to address the health and welfare of organic livestock with specific guidance and exceptions with regard to outdoor exercise and access to pasture (6.1.3, 6.11.1 & 6.13.1).


6.11 Additional requirements for cattle, sheep and goats

Outdoor access – Finishing phase

When herbivores are being confined in the final finishing phase (see 6.11.1 b)), and are not subject to pasture requirements, must the confinement facility be located on an organic enterprise? (116)
Yes. Compliance to the standard and verification by the CB is required of the areas used for finishing including all buildings, facilities and outdoor access areas which are utilized by the organic livestock. The remainder of the farm is not required to be organic.

Access to exercise yards

Must young herbivores be given access to exercise yards outside of the pasture grazing season (6.11.1)? (325)
Yes. Outside of the pasture grazing season, young herbivores must have access to exercise yards except if it can be demonstrated that doing so would jeopardize their health and/or welfare (6.11.1 c). Dairy calves must have access to pasture by 9 months of age (


Small breed exemption

Is the small breed exemption in Table 1 of 6.11.2 of 32.310 restricted to 'Dairy cows - individual maternity pens?'(329)
No. The exemption is applicable to the entire table. There was an editing error made during the last revision.


6.12 Addtional requirements for dairy cattle housing


Indoor pens for dairy calves

Can dairy calves be raised in indoor pens until such time as they are weaned? (317)
Yes, considering that weaning of calves cannot be done before the age of 3 months (6.4.3 c) and that dairy heifers aged 9 months and older must have access to pasture in season (


 Electric trainers

Are electric trainers allowed to manage animals in tie-stalls? (206) 
Electric trainers are prohibited by the standard in new constructions and renovations and can only be used in existing dairy tie-stall barns, with restrictions when they are part of a management strategy to keep cows clean and prevent disease, in accordance with the requirements of Use will be prohibited 5 years post publication date of 2015 standard - November 25th 2020..

Tie stalls 

Are tie stalls prohibited? (92)

Installation of tie stalls is prohibited. Existing tie stalls may continue to be used for lactating cows and for one month for heifer training before they join the milking herd, as long as the dairy cows are exercised daily whenever possible, or at least twice a week. 


Is to be interpreted as a requirement to allow cows housed in tie stalls a period of exercise every day when possible (at least twice a week) or merely a recommendation to do so? (92.1)

Yes,  is a requirement, not merely a recommendation. The intent of the standard is to require exercise for cows on a regular basis during the winter months. For an operator to fail to provide regular exercise would clearly violate the requirement.


What if it is not possible to exercise dairy animals daily or at least twice a week? (92.2)

There is a 5 year grace period from the date of publication of the 2015 standard by when operators must have loose housing for heifers and daily exercise for all animals. Within 12 months of publication there must be a plan for the new construction and either tethered cows are exercised daily or a minimum of twice a week OR no heifers or dry cows are ever tethered.


Does the one-year period after the publication of the standard apply to requirements 1 & 2 of section of b)? (291)  

By Nov 2016 the operator has to have submitted the plans for the new construction or renovation to address any structural changes needed. Because by Nov 2020 they must be exercising lactating cows at least twice a week and heifers and dry cows can no longer be tethered. So this is how it was to work:

1) As of Nov 2015, tie tall operations had to either start exercising tethered milking cows twice a week, or stop tethering heifers or dry cows.
2) As of Nov 2016, submit their plans.
3) As of Nov 2020, be exercising milking cows twice a week, and no tethering heifers or dry cows.


Ratio of cows to stalls

Do the requirements under CAN/CGSB-32.310 section 6.12.2 (ratio of cows to stalls shall not exceed 1:1) apply in a situation where dairy cows have access to the outdoors and an outdoor bedding pack year-round? (452) - 26 Sep 2019
Where a group of animals is housed in a free stall system, the 1:1 animal to stall ratio is required, regardless of outdoor access. This ensures during periods of weather-induced confinement that each animal can ruminate and rest.


6.13 Additional requirements for poultry


Length of immunization program

Is it permissible to
a) extend the vaccination schedule of a flock of pullets to 18 weeks even if the program does not need to be extended for any medical reason, simply to keep the birds from needing to be let outdoors?
b) eliminate the need for an outdoor run by extending the immunization program to 18 weeks in cases where the program can be shorter than 18 weeks? (412)

The answer is no to both questions. "6.13: Additional requirements for poultry" apply.


Space requirements – Poultry

Please clarify the outdoor space requirements for poultry. Can a flock be split so that use of the outdoor area is rotated between groups? If so, does the total area required diminish? (37)
While the standard allows for exceptions to the outdoor access requirements, (temporary confinement) the total area available for birds outdoors must allow for the entire flock to be outside at the same time without exceeding the densities set out in 6.13.9 - tableau 4 - for all poultry.


Measurement of outdoor space

Does the outdoor space requirement for poultry described in 6.13.9 refer to the total pasture area available for the year, or to the total area available at any given time? In other words, if an operator is rotating poultry between pastures, is each pasture required to meet the space requirements, or is it calculated from the total pasture that will be available throughout the year? (425) - 19 Apr 2019
6.13.9 refers to the total area available at any given time and does not include the pasture the flock cannot access. Read 6.13.11 for further insight.


Calculation of floor footage in multi-level aviary

Does a raised floor above the nests in a multi-level aviary count in the overall square footage as well as for the perch length? (360)
Yes. Per 6.13.10, the calculation of total floor footage includes all useful floor levels including perches.


Floor space in multi-aviary systems

For multi-level aviary systems for layers (6.13.10):

If winter gardens are accessible all year round, are they counted as indoor space, or part of the outdoor run/space? (410.1)
Depends where the winter garden is. If inside (e.g. greenhouse) it counts as indoor space. If outside (e.g. protected area on pasture) it counts as outdoor space.

Does space on ramps or ladders count towards useable floor space? (410.2)
No. Ramps and ladders are not floor space.

Do terraces under which manure collects and is not removed count towards useable floor space? (410.3)
No. As manure collection should take place in all spaces used by animals, areas such as terraces under which manure collects and is not cleaned out does not count as useable space.


Calculation of poultry densities

Are the poultry densities in Table 4 of 32.310 per flock? Or averaged over a year? (415) - 19 Apr 2019
32.310 6.13.9 Table 4 states maximum densities at any given time. This aspect of the standard is currently under review.


Parallel livestock production

Can organic meat birds be raised on the ground floor with access to the outdoors and non-organic birds raised on the 2nd and 3rd floor of the same barn? (393)
Using the same barn for organic and non-organic poultry production would be very difficult to achieve. For the ground floor of a barn to be considered a "separate production unit," complete separation would need to be ensured and documented. This would include having completely separate watering systems, air flows, pest control, biosecurity, effective equipment systems for dust control, feed and input delivery, storage, and preparation activities. Clear identification and separation of flocks would be required by breed and/or by stage of production


Justification to keep poultry confined indoors

Is there a temperature difference between the inside of a poultry barn and the outside environment (for example, a 2 degree C differential) that will allow operators to keep poultry confined indoors? (368)
No. A slight temperature difference in and of itself is not sufficient justification to keep poultry confined indoors, because other factors, such as relative humidity, rainfall, wind velocity, presence of predators, etc., must also be considered (6.1.3, 6.7.2, and 6.13.1).


Organic layers confined indoors

Is it permitted to raise organic layers confined indoors up to peak production based on 32.310 6.13.1.f) & g)? (427) - 19 Apr 2019
Yes. If it can be demonstrated that the layers are accessing the outdoors by the time of peak production. However, the rearing facility should closely match the conditions in the layer barn, including having access to an outdoor run (6.13.1 g). It is important to understand it is only permitted to keep the pullets indoors as an exception (i.e. when it is necessary for the immunization program and to ensure birds are confident in their laying sites).


Confinement - Laying period

Can hens be confined for part of each day during the laying period? (226)
Restricting outdoor access of laying hens, during day time hours, may only occur during onset of lay as per 6.13.1 f) or for reasons outlined in 6.7.2 . Further restriction of outdoor access is not permitted.


Urgent confinement of organic poultry

Can a regional authority make the decision that organic poultry must be confined (kept indoors) based on an imminent threat to the health of the birds, and would this be sufficient to establish the requirements needed for emergency confinement of all organic poultry in a given region, as per 6.13.1 d)? (440) - 21 June 2019
No. Ultimately each operator must make the decision that an imminent threat to health and welfare exists, and document the reasons and the length of the confinement. A documented 'High Risk' alert from a regional poultry authority may be used as one of the documented reasons for emergency confinement, but the decision to confine must be made by each operation individually.


Outdoor access for laying hens

Are laying hens required to have outdoor access for 1/3 of their laying-life as stated in the English translation of 6.13.1 f) in 32.310 or 1/3 of their life as stated in the French translation of 32.310? (414)
One third of its laying life (per the English version).


Encouraging birds to go outdoors

How should ‘managed in a way that encourages use by the birds’ in 6.13.1 c) 3) be understood? Would management practices such as running electric wire in front of the openings to the outdoors (to prevent crowding along walls and in corners) or raising openings to the outdoors to above the eye level of hens standing on the floor  (to prevent pests entering the barn) be compliant with the requirement of 6.13.1 c)? (413) - 19 Apr 2019
No. Management practices or structural impediments such as those cited in the question would hinder movement of the birds and thus are prohibited. There are many ways to encourage the birds to use the open-range; here are some practices to consider:
- Put in place cover on the range in the form of trees, shrubs or constructed shade to protect the birds from avian predators.
- Provide outdoor access or a covered porch to get the pullets outside and make them comfortable with the range they will have access to as adults.
- Provide separation in barns and runs to create multiple segregated flocks (i.e. 3000 to 5000).


Popholes are mandatory

When organic layers are pasture raised throughout the grazing season can the flock be housed during the non-grazing season in barns without popholes or other means of accessing the outdoors? (478) (April 29 2020)
No. 6.13.5 states "Poultry barns shall have sufficient exits (popholes) to ensure that all birds have ready access to the outdoors." As per 6.13.1 d), access to outdoors may only be restricted when outdoor access results in an imminent threat to the health and welfare of poultry.


Laying hens sold for organic meat

In order for spent organic laying hens to be sold at the end of their laying life for organic meat or organic processing, are they required to meet the requirements in 6.13.1 h) that barn raised meat chickens have daily outdoor access by 25 days of age? (411) - 19 Apr 2019
The issue of spent hens has not been specifically addressed in the standards and will be during the current review. Pullets with access to outdoors (6.13.1 h) - 2nd sentence) would easily meet the requirements for meat birds. Pullets that are confined miss the intent of the requirements and therefore cannot be sold as organic meat (6.13.1 h - 1st sentence). Another approach is a comparison on life cycles. As 25 days represents approximately 2/3 of the life of a meat bird raised to an average of 40 days, this means that for approximately 1/3 of its life (15 days), this bird must be able to get outside. Based on that logic, a spent hen slaughtered at 18 months of age (548 days) would have needed to spend 183 days outside to qualify as organic meat, unless weather conditions endanger the health or safety of the birds.


6.14 Additional requirements for rabbits

Space requirements for rabbits

Why are the space requirements for rabbits the same at all ages when other livestock in the standard have different space requirements for different ages? (458.2) (February 17, 2020)
Due to the short period from kit to slaughter of rabbits, it seems impractical to have an interim stocking rate requirement during this period. When the standard was first written, the only reference standard that had different requirements for different ages was assessed to be a lesser standard and so these were not adopted. There have been no requests from the industry to create these distinctions.



  Specific production requirements

7.1 Apiculture



Does the three year transition period apply to apiaries? (121)
No. The apiary site must comply with which specifies that 12 months of organic hive management is required prior to the harvest of organic honey.


New production sites in apicultural operations

When a certified organic apicultural operator wants to add new production sites, does the application for those new sites need to be received 12 months prior to first harvest of honey on the new sites? (312a)
No. Organic operators just need to list new production sites (fields, gardens, etc.) on their annual application for certification to be inspected along with the rest of the operation.

Does the CB need to inspect new sites before they are added to an existing organic honey operation? (312b)
No. The operator must document that the new sites comply with organic standards, and include this documentation in their annual application for certification.


Buffer zone

Is a transition period required between the last use of a prohibited substance in the buffer zone and the time when the bees are feeding? (124) (278)
No. There is no set transition period required for the apiary buffer zone. No prohibited substances, other than fertilizers (see 7.1.10), can be present when bees are foraging. As such, consideration must be given to chemically persistent materials previously applied that could still present harm to the bees.  For example, the nectar and pollen of plants grown from seed treated with neonicotinoid pesticides can contain residues of the pesticide.


Does any use of a prohibited substance within 3000 meters of an apiary automatically disqualify the honey from achieving compliance with the standard? (115a)

No - not always. All types of fertilizers are allowed. However, sewage sludge, GE crops and agricultural pesticides that prohibited by the standard, including systemic seed treatments, are not allowed (7.1.5). Other sources of potential contaminants should be assessed as to the level of risk they present. For example, if the risk of contamination is low, products prohibited by the Standard that are used by households within the buffer zone and be tolerated.


What potential contaminants are specifically prohibited, and which ones may be assessed according to the risk they pose? (115b)
Agricultural pesticides, herbicides and systemic seed treatments, sewage sludge, as well as GE crops within the buffer zone always result in non-compliance. Potential contaminants used by neighbouring home owners and other non-agricultural prohibited substances can be assessed as to the risk they pose to the bees and the honey. Low density rural residences within the  buffer zone may not present a significant  risk if it can be established (e.g. with an affidavit) that there is no use of prohibited pesticides or herbicides on forage plants.

Organic honey production typically cannot take place if the following are found within the buffer zone: high density housing areas such as subdivisions  golf courses, garbage dumps or landfill sites, industrial complexes, very busy roads, or commercial non organic greenhouses/nurseries. There may be extenuating circumstances that must be assessed by certification agencies in each case. If natural features, such as forests, hills or waterways, restrict the likelihood of bee travel and abundant organic forage are present, buffer zones of 3000 m may be reduced.

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What potential sources of contaminants within the buffer zone need to be considered? (115b)
Organic honey production typically cannot take place if the following are found within the buffer zone: high-density housing areas, such as subdivisions; golf courses; garbage dumps or landfill sites; industrial complexes; very busy roads; or commercial non-organic greenhouses/nurseries. There may be extenuating circumstances that must be assessed by certification agencies in each case.
Buffer zones of 3 km may be reduced if natural features restrict bee travel and abundant “compliant forage” is present (7.1.10a). In this context, “compliant forage” means flowering plants that meet the requirements of the standard even if they are not certified organic.


Adding a nucleus hive

When adding a nucleus hive to an existing organic apiary, shall it be considered as introduced bees (which are subject to commercial availability) or a replacement colony (which must be produced within operation or another established organic apiary)? (432) - 19 Apr 2019
An added nucleus hive (including both a queen and other bees) would be considered a replacement colony and therefore would be required to be produced within the operation or obtained from another established organic apiary (7.1.9).


Treated hives

Reading clause, does the term "treated hive" apply to the containers present at the time of the treatment only or does it also apply to any clean or untreated temporary containers, such as honey supers in summer time, and unused frames? (391)
The term "treated hive" applies to the container(s) present at the time of the treatment, and not to supers or frames removed from a hive prior to treatment. However, the wax from any honey super frame or brood frame of the treated hive present or added during the 12-month transition period would need to be replaced with organic wax at the end of the transition period in order to return to organic production.
The bees in the colonies, that is the hives plus bees, that were treated must also complete a transition period ( in 32.310)


Non-organic sugar for feeding colony b) permits the use of non-organic sugar for colony feeding under certain conditions. Does this exception allow the use of sugar derived from genetically engineered beets? (363)
No. The allowance in b) is for non-organic, non-GE sugar to be used as the GE prohibition in 1.4 supersedes.


Organic beewax

Can beeswax be certified as organic? (442)
Yes. Beeswax generated by organic apiculture operations can be certified organic (7.1.1) with two exceptions: 1) when comb foundation was not sourced from organic hives (; and, 2) when hives have been treated with synthetic allopathic drugs (


7.2 Maple products

Buffer zone

How close to a certified sugar bush can the use of a prohibited substance be allowed, without compromising the certification of the sugar bush? Are buffer zone needed? (13)
A sugar bush has the same buffer requirement as other crops. A minimum of 8 metres is generally required. However, this can be reduced if there are features that effectively buffer the sugar bush, such as permanent hedge rows, windbreaks, or roads (5.2.2). Also, depending on the circumstances, more than 8 metres may be necessary to prevent contamination.

Magnetization of maple water

In maple production, is it permissible to use an anode that magnetises maple water in order to keep the minerals in suspension and prevent calcareous deposits in the pan? (304)
No. It is prohibited to use technologies that may alter the intrinsic qualities of the product (7.2.7) and magnetisation has that potential.

Use of filtrate for cleaning

Can the filtrate be used to clean evaporators during the season? (215)
Yes, the filtrate (water that passes through the membrane in the osmosis technique of removing water from sap) may be used to clean the evaporator ( a 3))


Well water through reverse osmosis

Does well water meet the criteria for potable water if it has been run through a reverse osmosis filtering system? (430) 19 Apr 2019
Yes. Water purified by reverse osmosis is considered potable.


Rinsing and cleaning of osmosis membrane

Is it necessary to verify the quality of water used for cleaning/rinsing the osmosis membrane in maple equipment? (230)
Yes. If water is used during the production season, for cleaning/rinsing the osmosis membrane, potability needs to be confirmed (i.e., it must meet drinking water standards). ( a 3)


Heating option for maple syrup evaporator pans

Can natural gas be used to heat maple syrup evaporator pans? (346)
Yes, heating options, such as wood, heating oil, electricity, propane and natural gas, etc., that do not negatively affect the integrity of the syrup are permitted.


Waxed cardboard as fuel

Can waxed cardboard pellets be used as fuel in maple syrup evaporators? (373)
Yes. As long as the operator can demonstrate that this type of fuel does not affect the integrity of the maple syrup.


7.3 Mushroom production

Disease control

In the production of organic mushrooms, can table salt be used as a spot control measure for disease on mushrooms? (132)
Yes. Refer to the “salt” listing in PSL Table 4.3.


Does the substrate for organic mushrooms need to be a) certified organic, b) composted? Can conventional straw be used as compost feedstock for a composted substrate used to grow organic mushrooms? (4) (178) 

Standard through outlines the requirements.

 Wood  No, but must be free of prohibited  materials.  No
 Manure  5.5.1 (32.310) outlines acceptable  sources. Organic must be used if  available.

 Yes, and:
 1) the compost feedstock requirements  in PSL Table 4.2 apply: and,
 2) Either the ‘compost produced on  farm’ or the ‘compost from off-farm  sources’ criteria in PSL Table 4.2 apply.

 Other agricultural  substances (hay,  straw or grains etc)  Yes if available.

 1) If organic is not available then the  materials must be composted.
 2) If composting the:
 a) the compost feedstock requirements  in PSL Table 4.2 apply; and,
 b) either the ‘compost produced on  farm’ or the ‘compost from off-farm  sources’ criteria in PSL Table 4.2


Non-agricultural substances as mushroom substrate

Can non-agricultural substances including peat moss be used as a mushroom substrate/growth media or as a casing layer on top of a mushroom bed without being composted first? (385)
Peat moss is a substance in Table 4.2 of 32.311 which has no specific use or restriction of usage. Therefore, it can be considered as an applicable entry for mushroom production under 7.3.1 of 32.310. Other non-agricultural substances of Table 4.2 can be considered as well unless their annotations restrict the substance to a specific usage which does not include mushroom production. Composting is only mandatory for substances of conventional agricultural origin in mushroom production (


Spawn marketed with growing substrate

When marketing mushroom starter materials containing living spawn (e.g. mycelium loose in grain/or sawdust or embedded in a grow block/log/loaf/brick) as organic, are the components other than the mycelium exempt from the calculation of total percent organic ingredients in the final product? (471) (February 17, 2020)
Mushroom starter materials in any format do not fall under Clause 9, therefore a calculation of percentage of organic ingredients is not applicable. Spawn must comply with 7.3.3 and the makeup of the starter material must comply with 7.3.2.


Feather meal as mushroom substrate

Can feather meal, compliant with table 4.2, be used as a mushroom substrate without being composted? (344)
Feather meal made from organic poultry could be used as a mushroom substrate without being composted. 32.310 requires that other sources of feather meal be composted.


Non-organic Potato Dextrose Agar to propagate mycelium

Can non-organic Potato Dextrose Agar (PDA) be used to propagate mycelium (non-fruiting genetic material) to produce organic mushroom spawn?
If so, can it include compounds and micronutrients that are not listed? (451) - 26 Sep 2019

Yes. Non-organic PDA is permitted if it can be demonstrated that organic is not commercially available and the non-organic PDA does not contain GE ingredients (see Table 4.2, Agar) or compounds not listed in Table 4.3 of 32.311 (see 32.310 7.3.3).


7.4 Sprout, shoots and micro-greens production

Parallel production

Can organic and conventional sprouts be produced in parallel in the same facility if grown in visually distinguishable containers? (211)
No. Growing organic and non-organic sprouts of the same plant variety at the same time is parallel production and is prohibited. Where different varieties of the same species are produced simultaneously, the organic and non-organic crop themselves must be visually distinguishable.

Sprouts or shoots

Please describe the difference between shoots and sprouts. (191) 
Unlike sprouts, which are usually grown in water, shoots tend to be grown in a growth medium, such as a potting mix. Shoots tend to be cut, while sprouts are harvested and consumed with the roots attached. Production for both must comply with all criteria in 7.4 (Sprouts, shoots and microgreens production).


Plants sold in pots

Plants harvested within 30 days of planting fall under clause 7.4 and require the use of organic seed. What if they are sold in pots to a customer who keeps them beyond the 30 days? Would they still need to be grown from organic seed? (293)

If the plants are not "generally harvested within 30 days of imbibition" they do not fall under 7.4 (shoots and microgreens) and the organic requirements in 5.3 a) apply

Seed cleaning

Can synthetic acetic acid be used for the cleaning of seeds used for sprouts, as seeds are neither considered as food nor as a plant (PSL Table 7.3)? (210)
No. Only substances listed for seed cleaning in Table 4.3, such as peracetic acid, may be used (see


Substances for sanitizing seeds for sprouting and sanitizing sprouts, shoots, microgreens

Which substances are compliant for sanitizing seeds for i) sprouting, ii) shoot and microgreen production, and iii) for sanitizing harvested sprouts, shoots or microgreens? (303)
Substances used for these activities are limited to the following Table 4.3 substances: hydrogen peroxide and peracetic acid (peracetic acid listing) and hot water (water listing) (32.310 Chlorination of water shall not exceed maximum levels for safe drinking water. (Table 7.3).


Sprout rinsing

Does the requirement for water quality in and apply to all uses associated with sprout production?  Could water for rinsing be exempt from this description? (84)
The provisions apply to all stages of production of sprouts. Water for rinsing is not exempt.

Is the rinsing of sprouts with chlorinated water allowed? If so, in what concentration? (150)
Chlorinated water may be used to rinse sprouts ( provided the level of chlorine does not exceed the limit for safe drinking water (see 7.4.3 referring to 8.2, and 8.2.1 connecting to the ‘chlorine compounds’ listing in PSL Table 7.3).


Soil volume in microgreen production

Is the soil container volume criteria outlined in 7.5.5 (32.310) applicable to containerized microgreen production (7.4)? (400)
No. 7.5.5 is applicable to containerized, staked crops grown in greenhouses. The same logic would apply to containerized staked crops grown outdoors. But this definitely does not include microgreens. Nonetheless, if substrate is used for microgreens production, it has to be soil and comply with 7.5.2, 7.5.3 and 7.5.4.


Inert substances and materials as growing media

Can inert substances and materials be used in production of sprouts, microgreen and shoots under 7.4.1 (produced in water)? For shoots and microgreens under 7.4.2 (produced in soil)? What about growing on burlap cloth? On coconut coir/fibre? Can the 'soil' (7.4.2) be sterilized? (299)
For water-based sprout, shoot, and microgreen production systems (7.4.1): inert containers made of stainless steel and food-grade plastic are permitted. No growing media, such as burlap, coconut coir, coconut fibre (inert or not) are permitted in water-based sprout, shoot, and microgreen production systems. For soil-based shoot and microgreen production systems (7.4.2): the growing media must meet the definition of soil as defined in 3.62 (32.310): A ‘mixture of minerals, organic matter and living organisms.’ This means the soil cannot be sterilized (which would kill the living organisms). Burlap, coconut coir or coconut fibre could be used as part of the 'soil' or could function as the 'container' in a soil-based shoot or microgreen production system. The operator must confirm that these materials are free from and/or have not been treated with prohibited substances.

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Can inert substances and materials be used in production of sprouts, microgreen and shoots produced in water? For shoots and microgreens produced in soil? What about growing on burlap cloth? On coconut coir/fibre? Can the 'soil' be sterilized? (299) (358) 
For both water-based and soil-based systems inert containers made of stainless steel and food-grade plastic are permitted (7.4.3). Growing media use is restricted to soil-based systems (7.4.6) and
must contain “both a mineral and organic fraction” (7.4.6). Thus sterilizing the ‘soil’ would be counter indicated considering the likely presence of beneficial organisms in the organic fraction required in the growing media. Burlap, coconut coir or coconut fibre could be used as part of the 'soil' or could function as the 'container' in a soil-based shoot or microgreen production system. The operator must confirm that these materials are free from and/or have not been treated with prohibited substances.



Organic bean sprout production

Can bean sprout grown hydroponically be certified organic? (245)
Hydroponics is defined as the "cultivation of plants in aqueous nutrient solutions without the aid of soil" (3.29). As nutrient solutions cannot be used in organic sprout production (, it is not considered hydroponics. 7.4 addresses the production of sprouts.



7.5 Greenhouse crops 

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7.5 Crops Grown in Structures or Containers

Soil/soil-less mix

Can a greenhouse operator take soil from outside and move it into the greenhouse? (267)
Yes, providing the soil has not been exposed to substances prohibited by the Standard for 36 months.

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Can a greenhouse operator take soil from outside and move it into the greenhouse? (267) 
Yes, providing the soil has not been exposed to substances prohibited by the Standard for 36 months. (See ‘soil’ listing Table 4.2 – column 1).


Does the use of a “peat moss/compost etc. mix” satisfy the requirements of 7.5.4 for “soil used in a container system”? (25)
No. 7.5.4 allows for container grown production with soil. A compost and peat moss mixture is missing the mineral fraction that is required  for a “soil used in a container system.” (see 3.62, definition of soil). Soil as defined in the standard is not required for plant propagation or for transplant production.

Does the use of culture medium (which is soil-less, but otherwise comprised of organic matter) during the initial phase of propagation (2 – 3 weeks) preclude this type of production from organic certification as per the requirements of 7.5.4? (204)
The use of a culture medium, which does not meet the definition of soil but complies with the standard, is allowed in the case of plant propagation.


Use of a prohibited fungicide in greenhouses

If a grower covered the soil in a greenhouse container system and then sprayed a prohibited substance, can the soil be used in containers in subsequent cropping cycles if tests show that it does not contain any residues of the prohibited substance? (477) (June 29, 2020)
No. Residue testing cannot be used as a substitute for required organic management practices; organic operators must not apply prohibited substances as per 1.4.

Could this container soil be used for organic production after 12 months?
No. Even though the soil was covered, and testing was done 7 months later showing no residue - 36 months of transition is needed from the fungicide application for a compliant soil (see 'Soil' Table 4.2 of PSL). The 12-month period is only applicable to new operations per 5.1.1. Furthermore, keep in mind it is up to the CB if there was deliberate abuse alternating between organic and non-organic methods in this production unit which may lead to decertification. (See SIC Q&A #6)


Composition of growing media

Does a growing media containing a pinch of sand, 10% compost and the balance peat moss meet the requirement of 7.5.4? (454.2) - December 2, 2019
No. The intent of this clause was to establish the profile of the required soil structure to ensure sufficient air and water drainage and nutrient holding capacity. Please note that clarifying language is being developed for the 2020 revision of the standard.

May coconut coir be part of a growing media used in container growing systems? (454.3) -December 2, 2019
Yes. Coir may be used. It is covered by the "Plants and plant by-products" listing in Table 4.2

Could a soil media blend of coir, peat moss, perlite and compost be used to grow perennials? (454.4) - December 2, 2019
No. Soil used in containers to grow perennials should also contain a mineral fraction that is not covered by perlite. It should contain sufficient sand, silt or clay to contribute to the physical soil structure.


Disposal of greenhouse soil

Under 32.310 clause 7.5.12, can operators dispose of greenhouse soils in cases where there is a risk of disease or pest propagation? (465) (February 17, 2020)

Disposal of greenhouse soil to minimize the spread of a transmissible pest or disease is permitted only when a regulatory directive has been issued requiring such a practice "treatment" (32.310, 4.4.6). In the absence of such a directive, greenhouse soils must be re-used as per 7.5.12.


Soil volume

Under section 7.5.5 d. of 32.310, how should the soil volume be defined and how should the total growing area be defined? (286)
The calculation for soil volume requirement shall be done on the greenhouse's total area available for photosynthesis by plants. This includes not only the surface of containers but also the surface of alleys between rows of plants. It does not include header houses, service alleys (perpendicular to the rows), staff rooms, offices, propagation houses, or storage areas.

The soil volume requirement is expressed this way so that growers have a certain freedom depending on the staked crops they grow (tomatoes, cucumbers, peppers, eggplants), the varieties they grow, the planting density they choose, the alley width they prefer, etc. The requirement  must be met upon inspection of the operation, i.e. the inspector shall find an effective soil volume in place in the container, not a purchased volume. If part of the greenhouse is not occupied by crop production but could be, it can be excluded from the calculation.


Soil and compost requirement in greenhouse production

Is biochar in a soil mix considered part of the mineral fraction? (424a) - 19 Apr 2019
No. Biochar should be considered as organic matter.

Are worm castings and vermicompost considered compost, and could they be used for the 10% requirement in 7.5.5.a)? (424b) - 19 Apr 2019
Yes. As they are both "products of carefully managed aerobic processes" (see 'compost' definition 3.15). Please also refer to 32.311 Table 4.2 Worm Castings.

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Are worm castings and vermicompost considered compost, and could they be used for the 10% compost requirement in d ? (424b)
Yes, as they are both "products of carefully managed aerobic processes" (see 'compost' definition 3.19). Please also refer to 32.311 Table 4.2 Worm Castings.


Can the additional compost applications required in 7.5.5 b) be in the form of compost tea? (424c) - 19 Apr 2019
No. Compost tea does not contribute to organic content of the soil. Its use is twofold. A source of soluble nutrients and beneficial microorganisms.

Version 2020

Can the additional compost applications required for staked crops in a) be in the form of compost tea? (424c) 19 Apr 2019
No. Compost tea is not considered compost because it does not contribute to the organic matter content of the soil. It can, however, provide soluble nutrients and beneficial microorganisms.


Mineral fraction of soil in contenants

For container production systems in greenhouses is the mineral fraction requirement (7.5.4) met if the "soil" contains either perlite or vermiculite? (408)
No. That was not the intention of the standard. Even though both are heated forms of mineral compounds (perlite/volcanic glass, vermiculite/expanded mica) the requirement is some sand, silt or clay would be included in soil mixes.


Compost requirement

Under section 7.5.5 a) of 32.310, is the requirement of 10% compost by weight or by volume? (287)
The compost requirement of 7.5.5 a) is calculated by volume.


Forestry by-products as greenhouse compost

Can bark or forestry by-products alone fulfill the 10% compost criteria for greenhouse container growing? (461b) (February 17, 2020)
No. Compost is a product of a carefully managed aerobic process (32.310 3.15).


Scope of 7.5.5

Does 7.5.5 apply to determinate (non-staked) varieties, or only to indeterminate (staked) varieties grown in containers? (342.1)
7.5.5 covers containerized indeterminate varieties grown in greenhouses for an extended period (e.g. 7 months or more) and that are supported by a trellis system (e.g. stakes, strings or wires). 7.5.5 is not applicable to non-staked determinate varieties or crops with shorter production cycles (e.g. where harvest is finished within a period of less than 7 months).


Crops grown in production shelters

Is the greenhouse clause (7.5) applicable to berries grown in protective shelters? (454.1) - December 2, 2019
Yes. All applicable requirements in 7.5 must be satisfied excluding 7.5.5 which is specific for greenhouse vegetable crops that are containerized and staked. Please note that this topic is under review during the 2020 revision of the standard.


Artificial lighting as a supplement to natural light

Are systems reliant only on artificial lighting allowed under COS? (342.2)
Microgreens and shoot production may use systems reliant only on artificial lighting. For greenhouse crops, however, artificial lighting is permitted only as a supplement to natural light (see 7.5.6). Note: The organic greenhouse standards were not developed with growth chamber-like systems in mind. A persuasive petition for their inclusion would need to be submitted to the CGSB Organic Technical Committee for consideration.

Version 2020

Are systems that are reliant on only artificial lighting allowed under COS? (342b) 
Microgreens and shoot production may rely entirely on artificial lighting. For greenhouse crops, however, artificial lighting is permitted only as a supplement to natural light (see 7.5.4). Note: The organic greenhouse standards were not developed with growth chamber-like systems in mind. 


Parallel production

Does the exemption from the rule prohibiting parallel production allow greenhouses to transition only part of their operation? (109)

Yes, the propagation portion of the operation may practice parallel production per 5.1.4.

Is parallel production prohibited for greenhouse crops? (285)

The Standard prohibits parallel production in annual crops including those grown in greenhouses with exceptions outlined in 5.1.4. However, if visually distinguishable organic and non-organic crops are grown, this is considered to be split production (5.1.3), which is permitted if: greenhouse systems (air, water, etc.) are sufficiently segregated so as to eliminate contamination risk of the organic crop by prohibited substances (1.4).


7.6 Wild Crops

Wild seaweed

Can wild seaweed meal be certified? (244)
Yes, until January 14, 2021, seaweed meal can be certified under Section 7.6 Wild crops if it is used for food or livestock feed. After this date, seaweed products will need to be certified under the Organic Aquaculture Standard CAN/CGSB-32.312.


Buffer zone around wild crops

Can wild harvest sites be located less than one kilometre from potential sources of environmental contamination such as golf courses etc., if it is demonstrated that the wild crops are completely isolated from contact with prohibited substances by a clearly defined buffer, in accordance with section 7.6.4? (343a)
No. There is no latitude in 7.6.4 to reduce wild crop buffer zones, where required, to less than 1km.

In the event that wild harvest cannot be certified (if 1km requirement cannot be attained), is parallel production prohibited between crop production (plantation) and wild harvest? If so under what circumstances might it be allowed? (343b)
If the wild harvest cannot be certified, parallel production from an existing organic plantation would be permitted; however, a new organic plantation could not be established. (3.52, 5.1.4 and 5.1.5)


Weed control for wild crops

Can salt be used for weed control on ground here organic wild harvested crops are stored? (367) 

No. First, the wild harvest area is to be "relatively undisturbed" (7.6.3) so using salt as a 'herbicide' in the area, even on a rock outcrop is prohibited as it is would change the ecosystem. Second, salt is not authorized as an herbicide in Table 4.3.

Version 2020

Can salt be used for weed control on the ground where organic wild harvested crops are stored? Even if that storage area is on a rock outcrop? (367) 
No. First, the wild harvest area is to be "relatively undisturbed" (7.6.3) so using salt as an 'herbicide' in the area, even on a rock outcrop, is prohibited as it would change the ecosystem. Secondly, salt is not authorized as an herbicide in Table 4.


.Honey harvested from wild bees

Can honey harvested from wild bees be certified to the "Wild Crop" requirements in Clause 7.6? (382)
No. Wild animal products are not covered by the Canadian Organic Standards.


8  Maintaining organic integrity during cleaning, preparation and transportation

Staff training

Are CB's required to verify that staff working in facilities where both organic and conventional foods are processed have the necessary training to result in compliance with the standard? (130)
CB's are required to verify compliance with the standard. If in the course of inspecting a facility, it becomes apparent that staff who are responsible for maintaining organic integrity lack the necessary training needed to differentiate between organic and conventional processes, this could be the basis of a report of non-compliance. (see 32.310 - 4.4 and 8)

X-rays – Irradiation

Does the use of x-rays (at customs inspection) constitute irradiation under the standard? (45)
No. X-ray technology used to inspect at border crossings is not irradiation as defined in 3.33 and prohibited by 1.4).


Ultraviolet radiation

Is ultraviolet radiation of milk, cheese and fruit juice acceptable under the COS? (152, 338) -19 Apr 2019
Near and medium ultra-violet rays are classified as non-ionizing radiation and can be used to treat milk, cheese and juices. But neither near nor medium ultra-violet rays can be used to boil (7.2.14) or sterilize ( tree saps such as maple or birch. Far ultra-violet radiation cannot be used on organic products. All forms of ultra-violet radiation can be used to sterilize packaging prior to filling.


Use of microwave

Is the use of a microwave oven in organic food preparation compliant with the standard? (220)
Yes. While the standard prohibits ionizing radiation, the use of non-ionizing radiation such as that generated by a microwave oven is not prohibited. It is prohibited to boil maple syrup or products using microwaves (7.2.14)

Water - Filtration 

Can water that has been processed through an alkaline filtration system be used in the preparation or processing of an organic food product? (185)
Providing the resulting water falls within Health Canada's Guidelines for Drinking Water; pH 6.5 to 8.5 and no substances or processes prohibited by the standard are used or added, the water is acceptable.


8.2 Cleaning, disinfecting and sanitizing

Water – Vegetable rinsing

What are the requirements for water quality, where the water is used to wash organic vegetables? (128)
Water must meet the requirements for potability as per local, provincial or federal authorities..

Can chlorine be used to wash organic produce? (5)
Chlorinated water, up to the concentration permitted in municipal drinking water systems, is acceptable for washing organic vegetables and does not require rinsing. (see the chlorine compound listing in PSL Table 7.3).

Cleaners – Required removal

What are the requirements for removal when cleaners are approved for use under the provisions of 8.2.3 and are not listed on 7.3 or 7.4 of the PSL? (106)
The operator is required to document that the substances are efficacious and that the product has been effectively removed before organic products come into  contact with the surface. Examples of acceptable removal events include rinsing with potable water, letting surfaces drip dry and purging lines with organic product. . The operator is also required to neutralize any product before disposal to minimize environmental impact. Refer to 8.2.3 c. and 3.59 – the removal event definition. .

Cleaners – Milking equipment

What is the distinction between acceptable cleaning agents for milking equipment on farms vs. those used in processing facilities? (209)
8.2 gives direction for cleaning food contact surfaces which would be appropriate both on dairy farms and in off-farm dairy processing facilities.

Cleaning – Milk trucks

Is it necessary to wash milk trucks at a processing facility under the supervision of a certifying body in order to maintain certification of the milk? (108)
No. There is no requirement to wash bulk milk trucks specifically at a processing facility placed under the supervision of a certifying body. In order to comply with the standard, documentation that substances used in the cleaning process have been removed, must be maintained to demonstrate compliance to 8.2.


8.3  Facility pest management and post‐harvest management

Pest control – Bait station location

When pesticides allowed under section 8.4.3 (not listed in PSL) are used in a facility, is the fact that the bait stations are clamped to the wall sufficient to ensure that no contact occurs? (38)
No. Where a pesticide not listed in PSL Table 8.3 is dispensed using a “fixed bait station” the operator must ensure that neither the pesticide nor the contaminated pest could come in contact with the organic product. For indoor use, no organic products or packaging materials may be present during the use of the pesticide.

Pest management - indoor/outdoor

Does 8.3.3 only apply to substances for pest control used inside facilities or also to substances used on the exterior? (212)
8.3.3 applies to both indoor and exterior pest control for all operations that handle, store and transport organic products. The indoor/outdoor requirement is reiterated in the PSL (8.1.1). It is essential that pest control used around farm buildings and storage areas does not compromise organic product integrity or the surrounding farm environment. 8.3.3 does not apply to situations involving exterior pest control at facilities where it is unlikely that organic product integrity will be compromised, or the surrounding environment contaminated.


Pest control in food processing facilities

Clause 8.3.2 states that table 8.2 & 8.3 substances can be used in food processing facilities to control pests. Can substances listed in Tables 4.2 & 4.3 be used as well? For example pheromones (4.3) and sodium tetraborate (4.2)? (392)
No. Only substances in the table referenced are applicable. Please refer to CAN/CGSB-32.310 clause 8.3.3 for alternative pest control options for food processing facilities.



9 Organic product composition

Calculation of organic content – Aloe vera powder

Can Aloe Vera Juice or Gel made from organic aloe vera powder and water be certified as organic for human consumption? How is the organic content calculation done? (301.1)

Yes. A reconstituted Aloe vera juice or gel product can be certified as organic. If language stating that the Aloe vera “reconstituted from concentrate” is included on the principal display panel (PDP), the organic content of the juice or gel should be calculated using the amount of single-strength Aloe vera made from the concentrate. If the PDP does not mention reconstitution of Aloe vera, the organic content of the juice or gel should be calculated by subtracting the total volume of water from the final product. (9.1.3.b)

When Aloe Vera Juice (reconstituted from 200X Aloe Vera Powder and water) is used as an ingredient in a further food product, how is the organic content calculation for the secondary product to be done? (301.2)

Water used to reconstitute the powder should be excluded from the organic content calculation. For example, if 200 L of Aloe vera juice (reconstituted from powder at 200X strength) is used as an ingredient in a further juice product, only the 10 gram weight of the original Aloe vera powder would be included in the calculation of the secondary product. (9.1.3 c)


Gas as ingredient

Are gases (such as carbon dioxide for the carbonation of beverages) added as ingredients (under PSL table 6.3 or 6.4) required to be calculated as non-organic ingredients? (473) (February 17, 2020)
No. Gases are not included. Only solids and liquids must be accounted for when calculating organic content (9.1.3 in 32.310).


5% non-organic content

What are the restrictions on the up to 5% of non-organic ingredients allowed in production of organic products in the OPR? (16)
The use of non-organic ingredients should be kept to a minimum (9.1.1 in 32.310).  If and when they are used, the 5% of non-organic ingredients:
• must respect origin and usage requirements, as annotated in PSL Tables 6.3 and 6.4;
• if not listed on the PSL, must be non-organic agricultural ingredients for which the organic form is not commercially available. Such non-organic ingredients must comply with 1.4 a), c) and h) (see   9.2.1 in CAN/CGSB 32.310).

Constituents of ingredients - Calculation

In 9.1.2 of the standard, what does the term "constituent of an ingredient" mean? Are incidental components or carriers considered constituents? (131)
Constituents refer to all the components contained in an ingredient. Every constituent or subpart of every ingredient including carriers or preservatives needs to be included in the calculation of constituents’ percentages and reviewed with regard to compliance with the PSL.

Ingredients – Organic and non-organic

Does the prohibition against using both the organic and non-organic form of an ingredient (9.2.1) apply to different varieties of grapes used in a wine, or different flours (e.g. barley and wheat) used to bake a single bread? (173)

Under 9.2.1, ingredients that are recognized as having distinct qualities could be considered as separate ingredients, even when they fall into the same general category of ingredients such as "flour" or "grapes". In the examples given, it would be possible to use one ingredient in its organic form and the other in its non-organic form without violating9.2.1provided the following restrictions are satisfied. For organic products with organic content equal to or >95%, the non-organic content must be less than 5% of the total and commercial unavailability must be confirmed annually for any non-organic agriculture ingredients. For products containing between 70-95% organic content, commercial availability does not apply. In both categories, the organic and the non-organic ingredients must be listed on the label to be compliant with labelling requirements in the OPR and the guidelines from CFIA.

Meal replacement

Is a "meal replacement" certifiable under the COR, given that it contains supplemental minerals and vitamins? (266)
Meal replacement products may be certified organic if produced in accordance with this Standard and if they meet the nutritional profile set out by Canadian regulation for "meal replacement" products.


Fortification of organic food

Can juice formulated with Vitamin C or D, or calcium be certified as organic? (328)
It depends. The answer is yes, if the calcium compounds and Vitamin C (ascorbic acid) are being used as acidity regulators, stabilizers, preservatives per the individual listings in Table 6.3. The answer is no, if Vitamin C or D, or calcium are being added for nutritional fortification. Juice is categorized as a voluntary fortification option by the Canadian Food & Drug Regulations and the PSL 'Vitamins and mineral nutrients' annotation in 6.4 reads "shall be used if legally required". "Legally required" means fortification is mandatory by government and that is not the case for juices. Refer to CFIA’s Foods to Which Vitamins, Mineral Nutrients and Amino Acids May or Must be Added [D.03.002, FDR] and to the "Vitamins and Mineral Nutrients" listing in Table 6.4 for details.


Livestock feeds – Certification

Can livestock feeds which contain non-agricultural ingredients be certified? (65.1)
Livestock feed must meet the organic product requirements in Section 8 of the 9.1.3  d), and the labelling and advertising requirements in OPR section 24.  Livestock feeds may contain necessary feed additives or supplements according to PSL Table 5.2. Refer to 6.3 in CAN/CGSB for complete details on livestock feed.

Lactoserum for feed

Can non organic lactoserum be used as feed if it is documented that organic lactoserum is not commercially available? (258)
No. Livestock feed must contain 100% organic agricultural ingredients. (9.1.3 d)).

Processing Aids

When processing a product which will be sold as 70-95% or 95% organic, must the operator use processing aids listed on the PSL (Table 6.5) exclusively? (20)(20b)
When manufacturing a 70-95% or 95% organic product, all non-agricultural processing aids must be listed on in PSL 6.5 and all annotations complied with. Any non-organic agricultural processing aids must comply with 1.4 a, b, c and h, and if listed in PSL 6.5, must satisfy the annotations.

Does the standard require that processing aids in the production of non-organic ingredients be listed on Table 6. 5 PSL? (20a)
No. The processing aids used by manufacturers of  non-organic ingredients are not subject to the scrutiny of Certification Bodies.

Sodium free substitutes

Does paragraph 9.1.3  which excludes salt from the calculation of organic percentage, apply only to sodium chloride, or could a sodium free substitute, such as potassium chloride also be excluded? (165)
Yes. If the sodium free substitute serves the same purpose as sodium chloride, specifically to add flavor, nutrition, or microbial control, it may be excluded from the calculation (see 3.60 definition salt).

Ultraviolet radiation

Is the use of ultraviolet radiation to diminish microbial flora admissible in foods such as milk and cheese? (152)
Ultraviolet light is not food irradiation. It may be used to treat organic food such as milk and cheese, but it cannot be used to sterilize tree saps such as maple or birch (



Permitted substances lists - CAN/CGSB-32.311


General information

Brand name approval

What is the pathway for approving cleaners, or substances used? (3)
Operators should approach their Certification Bodies to verify brand cleaners comply with the standard. Approval of substances is the mandate of CGSB Technical Committee, through the Permitted Substances Lists working groups (Reference, PSL).


For soil amendments and crop production aids, is it enough that the active ingredients are compliant, or does the certifier need to review the list of inert ingredients and formulating agents? (168)
All substances contained in soil amendments and crops production aids must be disclosed by the supplier for review by the CB. Table 4.3, under the heading "Formulants" provides some guidance in evaluating non-active ingredients (inerts) in crop production aids.

Table Cross-Referencing

Does the inclusion of Calcium Phosphate (monobasic, dibasic and tribasic forms) on table 6.3 for use in processing imply that these substances can also be used as soil amendment or Crop Production Aids? (Tables 4.2 and 4.3) (140) (155)
No. An annotation in one table cannot be applied to a listing in another table.  The inclusion of substances on Table 6.3 for preparation does not make them compliant for other uses. However, Table 4.2 does list mined minerals, making the natural form of calcium phosphate (apatite) acceptable as a soil amendment.

Does the process described in Table 4.2 of the PSL (annotation for amino acids) apply to other microbial products, for example yeast, for use as a soil amendment? (57.2)
No. An annotation for one listing cannot be applied to another listing.


About ‘Origin and usage’

If there is nothing showing in the "origin and usage" column of the PSL, does this mean that any form of the substance may be used? In previous versions of the PSL there were restrictions on ascorbic acid regarding its non-synthetic or synthetic nature and this is what gave rise to our question. (423)
Yes. If nothing is written in the "origin and usage" column then there are no restrictions as to the origin and/or usage for that substance in accordance with the scope of the PSL table in which they are listed. In the case of ascorbic acid, the annotation was removed after new information indicated that all commercially available ascorbic acid is synthetic which made the annotation allowing both forms redundant.

Annotations to permitted substances

CAN/CGSB-32.311 Section 4.1.3 a) & 5.1.2. a) state that if a listed substance includes substrates or growth media, the substrates or growth media ingredients shall be listed in Crop Tables 4.2 & 4.3 and Livestock Tables 5.2 & 5.3. In this situation do the origin and usage annotations for these substrates or growth media ingredients listed in 4.2, 4.3, 5.2 and 5.3 apply? (389)
Yes. Substance annotations must always be addressed. One exception is pesticide formulants listed on PMRA Lists 4A, 4B and 3. The MAR 2018 amended standard clarifies that pesticide formulants on these three PMRA lists are not subject to 1.4 of CAN/CGSB-32.310. This means 4.1.3 a) is not applicable to pesticides made from microbial products containing some substrate or growth media as long those compounds used as a substrate or growth media are listed either on PMRA List 4A, 4B,or 3. However, there is no exemption from the requirements of 4.1.3 a) for microbial products used as fertilizers. In the case of an amino acid preparation fed to livestock produced on a molasses substrate and which contains molasses, the molasses must be organic (see 'Molasses' Table 5.2).





Permitted substances lists for crop production

4.2 Soil amendments and crop nutrition

Amino acids

Are amino acids permitted for crop fertility purposes? (337)
Yes. Amino acids are permitted for crop fertility purposes. Amino acids are substances requiring microbial action to make nitrogen plant available (see Amino acids, Table 4.2).

Amino acids produced by hydrolysis processes

Are amino acids produced by hydrolysis processes using sulphuric and phosphoric acid permitted? (422) - 19 Apr 2019
No. When used in crop production, amino acids cannot be produced by hydrolysis using chemicals such as sulphuric and phosphoric acid. See 32.311 4.2 and 4.3 Amino acids b).

Anaerobic digestate

Is the end product from an anaerobic digester or biogas digester acceptable for use as a soil amendment? (30)

Yes but, the feedstocks must be listed in Table 4.2 and if obtained from off-farm the digestate must meet the heavy metal restrictions as listed in Table 4.2 Compost from off-farm sources.
The product may be used as compost feedstock, or if not composted it needs to meet raw manure land application requirements outlined in 5.5.2. (see Digestate, anaerobic listing in PSL Table 4.2)


Can green char be used in organic agriculture? (Biochar) (139)
Yes. But only biochar generated from  forestry by-products which have not been treated or combined with prohibited substances. No other feedstock is acceptable. (see biochar PSL Table 4.2)


Activated biochar

Is activated biochar permitted? (377.1)
Yes, if the activation is done with permitted substances, activated biochar may be used. Additional requirements, such as the genetic engineering prohibition (1.4 a in 32.310) and annotation restrictions in the substance listing, would need to be addressed.
Can it be used as soil substitute in organic containerized greenhouse production systems? (377.2)
No, biochar cannot be used as a soil substitute as it does not meet the requirements of a soil/growth media (see 32.310 7.5.4). It may be used as a soil amendment as listed in 32.311 4.2.


Blood meal

In Table 4.2 blood meal is allowed only if sterilized. What does it mean for blood meal to be sterilized? (262)
The Fertilizers Act and Regulations requires that fertilizers and supplements not contain any substances likely to be generally detrimental or seriously injurious to domestic animals or public health. Blood meal is defined as "collected blood of slaughtered animals, dried and ground, containing not less than 12% nitrogen». Blood meal is considered to be "sterilized" if it does not 'present a risk of harm to human, animal or plant health or the environment'. Commercial manufacturing of blood meal requires a heating/drying phase to meet the definition of sterilization and the requirements of the Fertilizers Act and Regulations.


Calcium chloride

Is calcium chloride made from the purification of naturally occurring brine allowed under the listing of “Calcium” in Table 4.2? (384)
Yes and No. Yes. Calcium chloride that is purified from naturally occurring brine via evaporation is allowed. Such calcium chloride may be used to address nutrient deficiencies and physiological disorders. No. Other purification processes of naturally occurring brine that involve additional processing steps (e.g., bromine removal, sulphur oxide addition, use of strong acid precipitation agents or lime, etc.) render the calcium chloride synthetic according to the COS (see "Mined Minerals, unprocessed" in Table 4.2).


Evaluation of extractants

For substances used in crop production, does the scope of evaluation for extractants require assessment of all materials used or only those that remain in the final product? (443) - December 2, 2019
For substances used in crop production, only extractants that remain in the final product are subject to evaluation, unless extractants are specifically addressed in the substance annotation.


Guano - Dried deposits of guano

What is meant by “Shall be decomposed, dried deposits” in the Guano 4.2 PSL listing? Does it mean fresh dry deposits from wild bats or birds cannot be used? Or does it mean that the guano must have been decomposed in situ, not dried elsewhere? (434) -- 21 June 2019
Wild bat and seabird guano must decompose at the site of deposit, not be dried elsewhere, and have been in place for sufficient time to decompose and dry before collection. Collection shall not impact an active colony.


Prevention of salt buildup

Does the salt buildup restriction for ‘calcium’ apply only to calcium chloride? (336)
No. The restriction applies to any calcium product with the potential to cause a salt buildup


Multi-ingredient fertilizer- non-organic oilseed meal

When used in a multi-ingredient fertilizer, is the use of non-organic oilseed meal subject to the commercial availability restriction? (387)
Yes. Even when used as a component of a multi-ingredient fertilizer a commercial availability search is required as per the annotation for "Oilseed meals" (Table 4.2). Therefore, an operator wishing to use this fertilizer blend would need to perform a commercial availability search for a fertilizer blend that is fully compliant before using this product.


Definition of wastes from crops

Under "Plants and plant by-products" in PSL 4.2, does the restriction “Wastes from crops that have been treated or produced with prohibited substances may be used as composting feedstocks” apply only to wastes from crops or does it apply to all plant materials? What is the definition of “wastes from crops”? (388)
"Wastes from crops" is referring to vegetal matter (plant and plant waste) from any source


Compost feedstocks

With regard to materials other than livestock manure, are all the materials used to make compost required to be free from toxins, or can it be determined that some or all toxins present in the compost feedstock will break down and be purified during the composting process? (76)
The notes in PSL Table 4.2 (32.311) under the headings "Compost from off-farm sources", "Compost produced on the farm" and "Compost Feedstocks" give extensive instruction as to what is required, permitted or prohibited in the production of compost. The underlying assumption is that the composting process is capable of degrading some contaminants that are present in the original material. When materials are used that may contain persistent prohibited substances, it is the responsibility of the operator to document or "prove" the process of degradation. The notation allows for two possible methods; 1) analysis of the final composted material or 2) reference to scientific literature which establishes the common degradation of contaminants during the composting process. In the case of materials obtained from an urban setting, e.g. leaves or yard waste; it should be assumed that persistent chemicals, including pesticides are present and due diligence as outlined above should be practiced. It is the CB's responsibility to assess the risk and require documentation specific to each situation.

What documentation is required to substantiate common degradation of contaminants during the composting process as implied in table 4.2 "compost feedstocks"? (133)
Acceptable documentation would consist of published academic studies.  Claims made by manufacturers must be verified by independent research. Operators also have the option of analysis of the final product to confirm that no contaminants persist.

If GE plants are used in the production of compost, can that compost be used to fertilize organic farms? We are concerned with families who buy conventional food and add the household waste to their compost. (129)
The presence of GE plant material is strongly discouraged, but the possibility of use as compost feedstock is not eliminated. See Table 4.2, 32.311 "Plant and Plant by-products": "Wastes from crops that have been treated or produced with prohibited substances may be used as composting feedstocks". However compost is subject to the following restrictions under "Compost feedstocks": "When evidence indicates that composting feedstocks may contain a substance prohibited by 1.4 of CAN/CGSB 32.310 known to be persistent in compost, documentation or testing of the final product may be required.”


Human waste in compost

Can urine from unmedicated individuals be added into compost which is used in organic certified production? (401)

No. Human waste is not listed as a permitted compost feedstock (see "Compost feedstock" Table 4.2).


Biodegradable bags as compost feedstock

Can residential food waste collected in biodegradable bags be used as a compost feedstock resulting in compost for organic production? (302)
Yes, as long as the biodegradable bags and the residential food waste decompose effectively during the composting process.  If applicable, the absence of petrochemical residues may need to be confirmed by testing. (See Table 4.2 'Composting Feedstocks')


Coloured ink in compost feedstock

If tests demonstrate acceptable levels of heavy metals, foreign matter and human pathogens, as specified in Guidelines for Compost Quality, is compost made from Municipal Source Separated Organic (SSO) household waste, which is composed mainly of vegetal and animal origin but could contain some coloured newsprint (added to household containers to absorb moisture and odors), and possibly other prohibited substances, permitted? (470) (February 17, 2020)
No. Regardless of whether testing indicates acceptable levels of heavy metals, finished compost must conform to the compost feed stocks annotation, which, for example, prohibits paper with coloured ink other than yard waste bags. See 32.311 table 4.2 Compost feedstocks.


Testing of compost used as ingredient

When compost is used as an ingredient in a blended fertilizer product, should the analysis for heavy metals, foreign matter, and pathogens occur on the compost ingredient prior to blending or on the final blended fertilizer? (334)
Compost must meet the required specifications, regardless of whether it is applied directly to the soil or blended with other ingredients. Therefore, in the case of a blended product, the compost analysis shall be performed prior to blending with other ingredients

Forestry by-products as compost feedstock

Can bark or forestry by-products be used as a compost feedstock? (461a) (February 17, 2020)
Yes. Forestry by-products can be used as compost feedstocks providing it can be demonstrated they do not contain a substance prohibited by 1.4 of CAN/CGSB-32.310 known to be persistent in compost. Table 4.2 Compost Feedstocks


Heavy metal analysis of off-farm sourced compost

Is a heavy metal analysis required for each individual compost ingredient used in the manufacture of off-farm sourced compost? (353)
"No. It is not necessary to test each ingredient of a compost before the composting process. Heavy metal analysis is required at the end of the composting process, before it is blended with any other substances, such as potting mixes, minerals, other composts, etc. (See 'Compost from off-farm sources', Table 4.2.)


Dust suppressants

Can mineral oil be used as a dust suppressant in sulphate of potash? (96)
No.  Only non-synthetic substances or substances listed  in PSL Tables 4.2 and 4.3, such as lignin sulphonate, molasses, and vegetable oils may be used.

Elemental sulphur

Is mined elemental sulphur permitted as a soil amendment? What other sources of elemental sulphur are permitted? (321)
Mined (non-synthetic) elemental sulphur is permitted as a soil amendment, as well as reclaimed sources of elemental sulphur.

Expanded perlite

Is expanded perlite permitted under the listing of ‘Clay’ on Table 4.2? (335)
Yes. The physical expansion of perlite during its manufacturing is permitted as the process does not change the molecular structure of the substance.

Fish products – Citric acid

What forms of citric acid may be used as a pH adjuster in fish products? (146)
Both non-synthetic and synthetic forms of citric acid may be used. (see Fish meal, fish powder, fish wastes, hydrolysate, emulsions and soluble listing in PSL Table 4.2)

Fish products – Stabilization

The manufacturer of a fish product soil and plant fertilizer desires to stabilize the product by reducing the pH below 3.5.  Is this allowable? (114)
Yes. As long as the amount used is not in excess of what is needed to stabilize the product. (see Fish meal, fish powder, fish wastes, hydrolysate, emulsions and solubles listing in PSL Table 4.2)

Fish & kelp products – Preservative

Can Potassium Sorbate be used as a preservative in kelp and fish products used as fertilizers? (110.1)
Potassium sorbate can be used as a preservative in kelp and fish fertilizers provided it meets the non-synthetic definition in 3.39. The origin and usage annotations for both the “Aquatic plants and aquatic plant products” and the “Fish meal, fish powder, fish wastes, hydrolysate, emulsions and soluble” listings, in PSL Table 4.2, prohibit synthetic preservatives.

Definition of fish farm waste

What is the definition of “fish farm waste” used in the listing of “Fish meal, fish powder, fish waste, hydrosylate, emulsions and solubles” in Table 4.2? Does it need to be composted? (333)
Fish farm waste consists of sludge and mortal remains (fish, bones, scraps, carcasses, etc.) collected at the fish farm. Such waste cannot be used raw; it must be composted or processed before use. Manufactured fish by-products, such as processed fish meals or liquid fish fertilizers made with farmed fish and/or fish farm waste, do not have to be composted before use.


Lactic acid produced by fermentation and extraction

Is lactic acid produced by fermentation and extraction allowed under the Canadian Organic Standards? Is that lactic acid considered to be synthetic? (331)


Lactic acid produced by fermentation and extraction is permitted. Extraction processes must use permitted extractants (See Extractants, Table 4.2 and 4.3 and Extraction solvents, carriers and precipitation aids, Table 6.3). Lactic acid produced by fermentation and extraction is considered to be non-synthetic under the Canadian Organic Standards. Requirements with regard to substrates/growth media must be met. Chemical processes used to purify and/or extract substances are permitted as long as they do not create new molecules or involve processes specifically prohibited by the standard. (See synthetic substance, 3.65 (32.310)).

Gibberellic acid produced by fermentation and extraction

Is gibberellic acid produced by fermentation and extraction allowed under the Canadian Organic Standards? Is that gibberellic acid considered to be synthetic? (332)
Gibberellic acid produced by fermentation and extraction is permitted. Extraction processes must use permitted extractants (See Extractants,Table 4.2 and 4.3). Gibberellic acid produced by fermentation and extraction is considered to be non-synthetic under the Canadian Organic Standards. Requirements with regard to substrates/growth media must be met. Chemical processes used to purify and/or extract substances are permitted as long as they do not create new molecules or involve processes specifically prohibited by the standard. (See synthetic substance, 3.65 (32.310))


Minerals – Flotation reagents

Does the use of flotation reagents in extraction & purification of mined minerals render the product prohibited? Is a producer required to demonstrate the absence of flotation reagents in the final product? (189)
Minerals which have been extracted using flotation reagents that are not intended to form part of the mineral substance are allowed. Given that flotation reagents are removed and reused by the mining industry, the operator is not required to prove the purity of the final product.


About fused minerals

Are fused mineral fertilizers (created by heating and blending minerals) compliant to COR? (464) (February 17, 2020)
No. Unless specifically listed in the PSL, minerals that have undergone such a change are not permitted.


Meat meal

Can "meat meal" or meal made from animal products or by-products be used as a soil amendment? (144)

Yes. But the meal must be processed. Acceptable processes including composting, heat sterilization or drying. (see Meat meal PSL Table 4.2)

Microbial feedstocks

What are the requirements for feedstock used to create microbial soil amendments? (167.2)
The requirements for feedstock used to create microbial soil amendments are distinct for two separate groups of product; i) microbial products containing no residue of the substrate: for these, the feedstock should be non-GE if commercially available. ii) product in which the microbial is delivered along with a remnant of the feedstock : here feedstock materials must be listed on PSL Tables 4.2 or 4.3 and comply with any annotations. (see PSL 4.13)


If a blended, multi-ingredient soil amendment contains non-organic molasses, can it be used in organic production? (188)
No. Organic molasses is required (see Molasses PSL Table 4.2)


Non-organic spent brewers' grains as amendment

Can non-organic spent brewers' grains be used as a soil amendment? As a compost feedstock? (323)

To be acceptable for use as a soil amendment, non-organic spent brewers' grains must be non-GE and any non-agricultural substances added during the brewing process must be listed on Table 4.2 of 32.311 and comply with 1.4 a) and d) of 32.310. For example, diammonium phosphate (DAP) added during the brewing process would render spent brewers' grains non-compliant for use as a soil amendment in organic production. Non-organic spent brewers' grains from GE sources are an acceptable composting feedstock, as GE residues do not persist after the thermophilic stage of the composting process. See 'compost feedstock in Table 4.2).


Paper mill sludge

Can paper mill sludge be used on organic farms? (294)
No. Sludge from paper mills is not listed in CAN/CGSB-32.311, and is therefore not permitted for use on organic farms (32.310 1.4 d). Any synthetic extractants, solvents or additives used when generating plant by-products are prohibited, except as specified in the annotations of substances listed on Table 4.2.

Potassium sulphate

Can potassium sulphate which has not been mined, but manufactured by combining mined potassium chloride, mined sodium sulphate and water, be used as a soil amendment in accordance with the PSL? (166)
Yes. Potassium sulphate produced from combining two mined minerals is permitted (see 'd’ ) “potassium sulphate” under the potassium listing - PSL Table 4.2); however, in general, mined minerals may not be processed or fortified with synthetic chemicals except where specifically permitted in the annotation. Potassium sulphates made using reactants such as sulfuric acid or ammonia are prohibited. (see “Mined Minerals, unprocessed PSL” Table 4.2)

Soap in soil amendment

Can a compliant soil amendment contain soap? (397)
No. Soil amendments may not contain soaps. Although soaps are technically surfactants they do not meet the non-synthetic requirement in the surfactants listings in 4.2 or 4.3



Is sugar allowed as a soil amendment? (60.1)
Organic sugar only can be used as a soil amendment. An organic substance does not have to be listed on table 4.2 to be allowed as a soil amendment.

Sulphuric acid

Please outline the application for the use of sulphuric acid under the COS. (98) (50)
Sulphuric acid cannot be used to manufacture calcium sulphate (gypsum), or potassium sulphate (see individual listings in PSL Table 4.2). Nor can it used as a pH buffer (see “pH buffer” in PSL Table 4.2 & 4.3) except in fish products but only if vinegar, non-synthetic citric acid, phosphoric acid are ineffective. (see “Fish meal, fish powder, fish waste, hydrolysate, emulsions and solubles).

Synthetics in soil amendments

Can fertilizers used as soil amendment in organic production be supplemented with synthetic substances? (167.1)
No. If a compliant soil amendment is enhanced or changed using additional substances, those substances must appear on Table 4.2 in order for the resulting soil amendment to be compliant.


Non-synthetic mineral fertilizers in ion-exchange systems

Does running a non-synthetic mineral fertilizer through an ion-exchange system render the mineral fertilizer synthetic? (365)
Yes. The use of an ion exchange system involves chemical reactions and unless specifically permitted by the PSL (Table 4.2) is prohibited. The word "combining" in PSL table 4.2 for "potassium sulphate" allows potassium sulphate that has gone through an ion-exchange system


Tractor exhaust

Is tractor exhaust, injected into the soil, acceptable under the standard? (32)
Tractor exhaust may be injected into the soil only if all the components of the tractor exhaust comply with the standard and PSL. This means 100% pure biodiesel exhaust would be acceptable while exhaust generated by a petroleum gas engine would not.


Limestone from sugar processing

Under table 4.2 "Limestone", is "limestone from sugar processing" allowed without evaluating the manufacturing process? (306)

Lime from sugar processing and mined calcium carbonate are acceptable sources. Review of the manufacturing process is not required.


Rock phosphate

The listing for rock phosphate in table 4.2 restricts cadmium levels to 90 mg/kg P2O5.  Is that to be calculated on the total P2O5 or the available P2O5? (305)

The amount of P2O5 used in the calculation is the total amount, not the available amount.


Testing of ash

Do all sources of ash have to be tested for heavy metals? (448.1) - 21 June 2019
No. Ash from plant and animal sources is permitted without testing if the source is known and there is no risk of there being heavy metals in the source. Testing is required when the ash source is unknown or it is known there is a possibility of the ash containing prohibited substances. Testing is to ensure the heavy metal levels are within the limits established in the Guideline for the Beneficial Use of Fertilising Residuals.

May ash from plant and animal sources not meeting the heavy metal levels limits in the Guideline for the Beneficial Use of Fertilising Residual be used in organic crop production? (448.2) - 21 June 2019
b) No. Ash from plant and animal sources not meeting the heavy metal levels limits in the Guideline for the Beneficial Use of Fertilising Residual cannot be used in organic crop production.


Wool as mulch

Can conventional wool be used as mulch? (324)
Yes. Even though wool is not specifically mentioned in the mulch listing in Table 4.3, wool from either organic or non-organic operations could be used as a mulch.


4.3 Crop Production Aids and Materials

Acetic acid

Can acetic acid solution be used as a weed control product in organic production? (172)
Yes. Non-synthetic sources of acetic acid may be used for weed control. (see “Acetic acid” PSL Table 4.3). Be sure to follow any applications restrictions on the product label.

Biological organisms

Must biological organisms be living in order to be compliant under table 4.3 "Biological organisms"? (224)
No. Either living, dead or non-viable biological organisms are compliant.


Use of antibiotics in orchards

Is streptomycin allowed in apple production to control fire blight? (311)
No. The amended standard published MAR 2018 clarifies that antibiotics, including streptomycin, are prohibited in crop production. (see 'Biological organisms' 32.311 Table 4.3)


Citric acid

Can citric acid be used as a pH adjuster during the extraction of Fulvic Acid? (248)
Yes. Non-synthetic citric acid would be acceptable. (see Humates, humic acid and fulvic acid PSL Table 4.2)

Combined formulations

Can a pesticide and a fertilizer be combined under the COR? (110.3)
Yes. An operator wishing to use a pesticide in a fertilizer formulation must ensure that the requirements of 32.310 5.6.1 and 5.6.2 are fulfilled. Pest control substances listed on the PSL Table 4.3 can only be used when other cultural approaches fail and require the documented presence of the pest organism. Fertilizer applications must be applied according to plant's requirements based upon the plant’s growth stage.

Fish products – Fatty acids

If fatty acids are allowed in organic production systems as a pesticide (see soaps, PSL 4.3), are fatty acids allowable in fish and aquatic plant products used as organic fertilizers? (110.2)
Fatty acids from plant and animal sources are allowed in fish and aquatic plant products used as organic fertilizers. They are not allowed if they are from synthetic sources, such as fatty acids extracted using hexane. For a synthetic to be allowed as an ingredient in an organic fertilizer, the substance must be included on the PSL Table 4.2 or 4.3.

Formulants – Non-synthetic

Are non-synthetic formulants allowed in fertilizer formulations? (53.1)
Non synthetic formulants are allowed in fertilizer formulations. Synthetic formulants are also allowed if specifically stated in a substance annotation. (see Formulants PSL Table 4.2)

Formulants – Soil amendments & crop production aids

Can plant oils / plant extracts based herbicides contain PMRA list 4 A and 4 B formulants? (51)
Yes, the formulants listed in PMRA 4A and 4B can be used. See “Formulants” table 4.3.


Must pesticide formulants used in crop production listed on PMRA 4A and 4B tables be GE free? (281) 

No. The amended standard published MAR 2018 includes a derogation for PMRA List 4A, 4B and List 3 formulants (Table 4.3 -32.311).


Are the restrictions in the formulant listings in Table 4.2 & 4.3 only applicable when formulants are specifically mentioned in an annotation? Or do the annotations for formulants apply whenever a substance contains a formulant? Case in point, may repellents contain formulants?(483) (April 29 2020)

The formulant listings apply whenever a substance contains a formulant unless a specific derogation is identified in an annotation. In the case of repellents: PMRA List 4 formulants are allowed in Repellents listed in Table 4.3.


Non-complying formulants in pesticides

What is the status of a crop on which a pesticide was applied containing an active ingredient listed in table 4.3 of the PSL but also a formulant from List 3 of PMRA? (326a)
In most cases the crop cannot be certified because (with the exception of List 3 formulants in passive pheromone dispensers) only formulants from Lists 4a and 4b of PMRA may be used in pesticides allowed by table 4.3. However, if the List 3 formulant is covered by a different substance listing in Table 4.3 (e.g. essential oils and aloe vera gel under “plant extracts”, soap under “Soaps”, etc.) or Table 4.2 (talc under “Mined minerals”, etc.), the crop could be certified.

Will a 36-month transition period be required for the piece of land used for growing the plants on which this pesticide was applied? (326b)
A 36-month transition will not be required if the List 3 formulant is a substance that could be included in one of the substances categories of table 4.3 or 4.2.


Insecticidal soaps

Can insecticidal soaps that contain isopropyl alcohol, in addition to the fatty acids derived from animal or vegetable oils, be used in organic production? (75)
Yes, insecticidal soaps containing isopropyl alcohol can be used since isopropyl alcohol (1-Propanol) is a formulant (as per PSL Table 4.3) and is listed in 4B of PMRA.

Kaolin clay

Is calcined kaolin clay a permitted substance under Canadian Organic Standards? (223)
Yes. Calcined kaolin clay is allowed, but only if no synthetic chemicals were used or added during the calcination process. (See Kaolin clay PSL Table 4.3)


Calcination of kaolin 

Is calcined kaolin allowed as a crop production aid (Table 4.3) if synthetic chemicals are added prior to calcination, such as flocculating agents, bleaching agents, and fluxes? (386)
Kaolin clay, per the annotation in 4.3, cannot be processed or fortified with synthetic chemicals unless they are listed in Table 4.2. (see "Mined Minerals, unprocessed" in Table 4.2).


Is the delivery of pheromones confined to passive dispensers or is spray application allowed? (93)
Yes.  The annotation for pheromones limits the delivery to traps or passive dispensers. Spray applications are prohibited. (See Pheromones and other semiochemicals PSL Table 4.3)


Synthetic pesticides in pheromone traps

Are synthetic pesticides permitted in pheromone traps? (362)
No. There is no provision for the inclusion of synthetic insecticides in pheromone traps (see Pheromones and other semiochemicals, Table 4.3).


Hay preservatives with prohibited substances in an organic field

If a hay preservative containing prohibited substances is applied while baling, and the hay is being sold as non-organic, does the field lose its organic status? (445) - 21 June 2019
Yes. The field would lose organic status as there is no means to ensure the field will not become contaminated to some degree. Only hay preservatives approved for organic use or those containing active ingredients listed in 4.2, 4.3 & 5.2 are permitted.


Acceptable substances in biodegradable mulches

Can biodegradable mulches contain substances listed in PSL 4.2 or 4.3? (371.1)
If yes, do the annotations for those PSL 4.2 and 4.3 substances used have to be addressed? (371.2)
Annotation restrictions apply even if substances are used as components of a biodegradable mulching material. For example if embedding micronutrients into the material, the annotation for micronutrients must be addressed.


Mulches - Biodegradable

Does the listing of “fully biodegradable films” in table 4.3 PSL under mulches include films made from petroleum products? (60.2)
No. Biodegradable polymers and Carbon Black From GE or petroleum sources are prohibited. Only fully 100% biodegradable films composed exclusively of biobased substances plus formulants and ingredients listed in PSL Tables 4.2 and 4.3 may be left to decompose in fields. All other non-biodegradable or semi-biodegradable mulch films or films containing prohibited components must be lifted at the end of the growing cycle.
A temporary exemption though has been created allowing the continued use of biodegradable mulch not meeting these requirements to be left in fields without removal until January 1st, 2017.

Processes in the manufacturing of mulches

For a biobased biodegradable mulch, what are the acceptable processes in the manufacturing of the film? Could a biobased film become non-compliant because of the manufacturing process that would disqualify it from being used on organic farms? (284)


No. Biobased biodegradable mulches must meet the requirements listed in Table 4.3 of the PSL and have been evaluated according to the criteria specified in Clause 10.3, Table 8. These criteria give preference to non-synthetic substances and consider the environmental impact of manufacture but do not specify any current restrictions on manufacturing processes.

Plastic mulch removal

Can you clarify the requirement for removal of plastic mulch from fields? (44)

Only fully 100% biodegradable films composed exclusively of biobased substances plus formulants and ingredients listed in PSL Tables 4.2 and 4.3 may be left to decompose in fields. All other non-biodegradable or semi-biodegradable mulch films or films containing prohibited components such as biodegradable polymers, or Carbon Black from GE or petroleum sources, must be lifted before they begin to degrade.

Are bioplastic mulches, made from corn, accepted as “biodegradable films” that can be left to decompose in the soil? (79) (253)
To be acceptable as biodegradable and left to decompose in the soil, a bioplastic mulch made from corn:
1) cannot be made using GE plant material;
2) cannot contain substances such as biodegradable polymers, Carbon Black from GE or petroleum.
Mulches containing biodegradable polymers and Carbon Black from GE or petroleum sources which were considered to be compliant in 2014 can be used and left in fields without removal as a temporary exemption until January 1, 2017 (see Mulches PSL Table 4.3 in 311 and the definition of biodegradable in 3.10 in 32.310).


Kraft lignin in biodegradable planting containers

Is Kraft lignin allowed as an ingredient in biodegradable planting containers that are left in the soil to decompose? (352)
Yes. Most papers are produced using the Kraft process. If all other ingredients are listed in Table 4.2, planting containers that contain Kraft lignin can be left to decompose in soil. See Table 4.3 Biodegradable plant containers.


Microbial substrates

May a bacteria for use as an organic crop production aid, be produced using prohibited materials in the substrate?(141) 

PSL Table 4.3 allows the use of "Biological organisms", which includes bacteria, providing they are not genetically engineered.

The requirements for the substrate on or in which they are propagated fall into two distinct categories; i) microbial products containing no residue of the substrate: for these, the substrate feedstocks should be non-GE if commercially available. ii) product in which the microbial is delivered along with a remnant of the substrate: here feedstock materials must listed on PSL Tables 4.2 or 4.3 and comply with any annotations. (see PSL 4.13).

Neem oil

Can neem oil be used to treat powdery mildew in cucumbers? (268)
Registered neem based pesticides can be used as a Crop Production Aid based on the listing in Table 4.3 of the PSL "Botanical Pesticides", with restrictions noted in the "Origin and Usage" column. Formulants included in these pesticides also have to comply with PSL requirements.

Magnesium lignosulphate

Is Magnesium lignosulphate allowed under the listing of lignin sulphonates in Table 4.3 of the Permitted Substances List? (289)

Lignin sulphonates, including magnesium lignosulphate, are allowed as chelating agents for micronutrients, formulant ingredients or dust suppressants.


Sulphonates manufactured with non-listed substances

Are lignin sulphonates manufactured with non-listed substances (e.g. calcium bisulfate) permitted? (355)
All lignin sulphonates, except ammonium lignin sulphonates, are allowed, as crop production aids, if used as chelating agents, formulants, or as dust suppressants. (See' Lignin sulphonates' Table 4.3, and PSL 4.1.1 b).


Is Rotenone allowed for use in organics? (308)
Rotenone is a substance that qualifies under the annotation for botanical pesticides. However, in countries such as Canada, where rotenone products are no longer registered for agricultural use, they cannot be used for organic production.



It is listed that water is permissible. Can you please tell me if Seawater can be used in crop production? (23)
Yes. Table 4.3 of the PSL allows for water which would include seawater to be used as a crop production aid.

Sprout inhibitor – Clove oil

Is clove oil allowed as an organic sprout inhibitor for potatoes? (27)
Yes. Clove oil is listed in PSL Table 8.4 as a post-harvest sprout inhibitor.

Sprout inhibitor – Ethylene

Is the use of ethylene as a sprout inhibitor for onions and potatoes admissible? (43)
No. The use of ethylene is restricted to tropical fruit ripening and citrus degreening (see PSL Table 8.4).

Structural PVC tubing

Can PVC tubing be used as structural material to hold insect nets? (136)
Yes. PVC tubing may be used. The prohibition of poly vinyl chloride for mulches and row covers does not apply to the structural material that would be used to suspend the row cover.


Transplant containers

If paper containers are placed in the ground as transplant containers and allowed to decompose, what are the requirements for the paper? (187)
The requirements are the same as for mulch (see Q&As 60.2, 79, & 44). No glossy paper or coloured ink. Must be 100% biodegradable derived from bio-based sources to be left to decompose in the ground. There is a temporary exemption until January 1, 2017 for mulches containing biodegradable polymers and Carbon Black from GE or petroleum sources.

Weed barriers

Could a woven polypropylene weed barrier cloth be left in place for 3-5 years in an orchard or vineyard? (347.1)

Yes, it can be left in place as long as it doesn't start to degrade.

Can the same thing be done with 100% coconut fibre mats? (347.2)
If the coconut fibre mats do not contain any prohibited materials, they can be used and left to degrade in place.


Permitted substances lists for livestock production

5.2 Feed, feed additives and feed supplements

Acetic acid for acidifying drinking water

Can acetic acid be used for acidifying drinking water for animals? (201) - 26 Sep 2019

Yes. Non-synthetic acetic acid may be used to acidify livestock drinking water. (See 'Acids' Table 5.3).


Hydrogen peroxide for drinking water

Can hydrogen peroxide that is used to treat drinking water for humans but is not necessarily rated 'food-grade' be used to treat livestock drinking water? The hydrogen peroxide annotation in PSL table 5.3 stipulates "food-grade" is required. (486) (June 29 2020)
Yes, Hydrogen peroxide approved to treat drinking water for humans is considered equivalent to food-grade for the purpose of treating livestock drinking water.


Substrate for probiotics

Q: Can a non-organic agricultural substance such as whey be used as the growing media to manufacture probiotics used as a feed supplement or as an ingredient for food? (252)

It depends. Non-organic agricultural ingredients such as whey, can be used as the growth media or substrate to manufacture probiotics used as a feed supplement or as an ingredient for food, as long as their use complies with the requirements of 32.311 5.1.2 and 6.2.1, as follows:

a) if the probiotic includes the substrates or growth media, the substrate or growth media ingredients shall be listed in PSL tables 5.2 (feed) & 5.3 (health care), 6.3-6.5 (food). If listed in the PSL, any use of non-organic agricultural substances listed in the PSL must comply with substance listing annotations;

b) if the probiotic does not include the substrates or growth media, it shall be produced on non-genetically engineered substrates or growth media, if commercially available.

This means each substrate needs to be assessed individually for compliance. For example, whey residues are not permitted in a probiotic product because whey is not listed in the required tables. Whey would need to be organic under these circumstances. Probiotic products without whey residues are permitted without a commercially available search because at present there is no milk being produced from genetically engineered animals.


Amino Acids – DL-methionine

Is the use of DL-methionine from processes involving Genetic Modification allowed? (54)
No. Table 5.2 of the PSL allows for the use of synthetic DL-methionine, as a special exception subject to a review by the CGSB technical committee.  Section 1.4 a) prohibits products from genetic engineering.


Lysine for livestock

What forms of L-Lysine are permitted? (420)
Preference shall be given to sourcing high lysine grains, seeds, and legumes. Other forms of lysine, if they meet the requirements of 32.311 5.1.2, are permitted, including those produced by biofermentation which may involve the use of acids during lysine production and purification. Please note that this entire annotation will be reviewed by the CGSB Technical Committee at the next full revision of the standard.


Cobalt Sulphate

Does the prohibition of sulphates produced with sulphuric acid apply to cobalt sulphate used as a mineral supplement and for medical use? (22.1)

Table 5.2 of the PSL allows synthetic trace elements, such as cobalt sulphate for feed if a non-synthetic form is not commercially available. Table 5.3 allows any source for medical use.

Fish Products

Is the use of fish products as feed supplements allowed? (22.2)
Yes. Fish products are allowed as feed supplements, as operators must supply “a feed ration sufficient to meet the nutritional requirements of the livestock” (6.6.1 b)). Feed supplements must not be fed in amounts above those required for health of the animal at its stage of production as per 6.4.4 c). This limits the volume of the fish supplement that can be fed in the ration. Feed supplements are defined in the standard as ‘feed that is used in conjunction with other feed to improve the nutrition balance... “(see 3.21 for “feed supplement” definition).

Vitamin & Mineral Premixes – Preservatives

If vitamin and mineral premixes that do not contain preservatives are unavailable, how can organic farmers meet the nutritional needs of their animals? (65.2)
The annotations in the listing of Pre-mixes, Vitamins, and Minerals, trace minerals, elements in table 5.2 (PSL) make it permissible to use pre-mixes that contain preservatives, if no fully compliant product is available. See “Commercially Available” definition - 3.13 (32.310).


Sprayed substances on dry hay

Can stored organic hay be sprayed with substances listed in 4.3 and/or 5.2 of PSL? (381)
No. Only substances listed under "Hay or silage preservation products" in Table 5.2 of 32.311 can be used with dry hay. Although salt is not specifically mentioned in this annotation of "Hay or silage preservation products", it would be allowed for hay treatment, as salt is a livestock feed.


Propionic acid containing ammonium hydroxide

Is propionic acid containing ammonium hydroxide permitted as a hay or silage preservation product under CAN/CGSB-32.311 Table 5.2? (356)
No. The allowance in the PSL 5.2 listing 'Hay or silage preservation products' is for propionic acid, not for propionic products containing prohibited compounds such as ammonium hydroxide. 1.4 f) prohibits the use of "synthetic crop production aids and materials", except as specified in CAN/CGSB-32.311.


Yeast Derived Protein

Is a yeast derived protein included under the definition of micro-organisms and yeasts in section 5.2 of the PSL? (120)
A yeast derived protein is not a yeast; it is a protein. Protein for use in organic livestock rations must be organic (see “Protein feeds” PSL Table 5.2), and in compliance with 6.4.4 (32.310). Protein derived from organic yeast could be compliant with the standard, depending on the method of fractionation.

"Yeasts" are listed on Table 5.2. Are the derivatives of yeast, namely the yeast cell wall products, also allowed? (238)
Yes. Yeast and yeast cell wall products are allowed as feed supplements. Non-synthetic versions can be used if organic sources are not commercially available.


5.3 Health care products and production aids

Colloidal silver

Is colloidal silver allowed for use in livestock health care? (273)

Yes, the use of colloidal silver would fall under the "Minerals, trace minerals, elements" listing in PSL table 5.3.  But due diligence is required to make sure the form of colloidal silver is acceptable. Colloidal silver produced using electrolysis is allowed, as is colloidal silver produced by a biofermentation process as long as the Genetically Engineered restrictions specified in 1.4 a (32.310) are met. Both of these forms are consistent with the exception pertaining to nanotechnology provided in 1.4 b) 1) of 32.310.


Can uncertified garlic be used as a de-wormer in organic livestock operations? (7)

This standard permits the use of uncertified garlic as a de-wormer treatment under section 5.3 of the PSL, Botanical compounds.


Magnesium carbonate as anti-caking agent

Can magnesium carbonate be used as an anti-caking agent in salt when used for livestock? (467.2) (February 17, 2020)
Yes. As magnesium carbonate may be included in feed as a source of nutrition. (see "Minerals, trace mineral, elements" PSL 5.3)



If ketoprofen is used therapeutically, is there a withdrawal period? (449) -26 Sep 2019
No. Non-steroid anti-inflammatories such as ketoprofen are included in table 5.3 of the PSL. Products listed in the PSL do not require any withdrawal times unless specified in the annotation or on the product label.



Is Lanolin allowed for use on dairy cows teats? (55)
Yes. Lanolin may be used. The SIC is aware that lanolin or similar preventative balms are not listed in PSL Table 5.3; but simultaneously they are neither prohibited by 6.6.2 of 32.310.

Medical Treatment – Fish Products

Is the use of fish oil as medical treatment (to treat bloat) prohibited? Are fish based animal health tonics prohibited? (22.3)
Fish oil and fish based health products are allowed as veterinary medicinal substances under 6.6.10 c. (32.310)

Vitamin B

Is it acceptable to inject meat animals with vitamin B for the purpose of improving meat color? (33)
No.  Table 5.2 lists vitamins for “enrichment or fortification.”  Injection to improve the colour of meat is for cosmetic purposes, not enrichment of fortification.

Vitamins – Preservatives

Can a vitamin, containing a synthetic preservative be used in livestock feed? (81)
Yes. Vitamins, with no restrictions, are permitted for feed enrichment or fortification. (See Vitamins PSL Table 5.2)

Eggs – Ink Labels

Can ink be used to label organic eggs? (46)
Yes. Ink that does not contain prohibited substances may be used to label egg shells.

Barn Sanitizers

Is Citrus extract allowed as a cleaner or disinfectant in buildings for animal production? (68.1)
Yes. Citrus extract, included under botanical compounds in 5.3 (32.311) would be useable as a cleaner in livestock houses.(see 6.7.4 in 32.310).

What is the status of tables 7.3 and 7.4 regarding livestock production? (68.2)
Substances on Tables 7.3 and 7.4 can be used in livestock facilities as can substances in Table 5.3, but cleaning or disinfection of livestock facilities is not confined to these lists. Any effective disinfectant can be used to clean livestock facilities in the event of a reportable disease. See 6.7.4 - 32.310.

Zinc oxide

Is Zinc Oxide allowed as health remedy in organic livestock production? (279)
Yes.  Table 5.3 "Health Care Products and Production Aids" lists "Minerals, Trace Minerals, Elements". Zinc Oxide would fall under this listing.

Zinc sulphate

Can Zinc Sulphate be used as a treatment added to foot baths for livestock? (270)
Yes, as it is considered a mineral under the listing in Table 5.3 - Minerals, Trace Minerals and Elements.


Enzymes from genetically-engineered bacteria

Can enzymes such as phytase be compliant to the standard even if the enzyme is produced by genetically-engineered bacteria? (380)
No. Clauses 1.1 and 5.1 in 32.311 and 1.4 a in 32.310 apply to enzymes in Tables 5.2 & 5.3 in 32.311.


Thymol - Synthetic thyme oil

Can synthetic thymol (thyme oil) be used to prevent and treat hoof problems? (379)
Yes. Synthetic thyme oil (thymol) is permitted as it is included in Miscellaneous section of the "Animal Health Care Products and Production Aids" listings approved for use in livestock husbandry.


Bloat treatment

Is the use of poloxalene allowed as a bloat treatment for dairy animals? (492) - 18 August 2020

No - unless the requirements of 6.6.10 of CAN/CGSB-32.310 are met.


Propolis for health care

Can non-organic propolis and other bee products, except honey, be used as a livestock health care product? (496) - 18 August 2020

Yes. Non-organic propolis, pollen, royal jelly, beeswax and bee venom, may be used as a livestock health care product (Homeopathy and biotherapies, CAN/CGSB-32.311 Table 5.3). Honey though, if used for livestock health care, would have to be organic (Honey, CAN/CGSB-32.311 Table 5.3).


Permitted substances lists for preparation

Anti-caking agents for grated cheese

What anti-caking agents are listed in the PSL that can be used in grated organic cheese? (435) - 19 Apr 2019
Currently none.

Magnesium carbonate as anti-caking agent

Can magnesium carbonate be used as an anti-caking agent in salt when used for food? (467.1) (February 17, 2020)
No. Magnesium carbonate may only be used as an anti-caking agent in non-standardized dry mixes (e.g. seasonings) used in meat products with 70-95% organic content. (see "Magnesium carbonate" PSL 6.3).

Bone Char

Is the use of bone char allowed in the processing of organic sugar? (192)
No. Although bone char is a form of 'Activated charcoal', it is not allowed because it is not from plant sources as required in Table 6.5 of the PSL.


Can cellulose be used in any other way than the ones specified in tables 6.5 and 6.4 (Collagen casings) of the PSL, for example as a flow agent in grated cheese? (235)
No. Only specified uses are permitted.

Cheese Wax

Can a coloured wax containing paraffin waxes (hydrocarbon or microcrystalline wax) and a colouring agent be used to coat organic cheese? (154)
Paraffin wax may be used to coat cheese if other non-synthetic waxes, such carnauba, are not commercially available. (see Waxes PSL Table 6.5) The paraffin cannot contain synthetic colours, preservatives, bactericides or fungicides. Microcrystalline wax is prohibited.


For cheese production, can we use chymosin in a salt brine solution with sodium benzoate added as a preservative? (151)
Chymosin derived from genetically engineered micro-organisms is prohibited as per 1.4 a). Chymosin extracted from calf stomach linings is permitted and should be from an organic source when commercially available (refer to “Enzyme”  PSL 6.3 and 6.5).  As sodium benzoate is not listed on the PSL, allowed chymosin products may not be preserved with sodium benzoate. Additional requirements outlined in PSL 6.2.1 must be addressed if the production of allowed chymosin products involves the use of substrates or growth media.

Fermentation-produced chymosin

If a cheese producer makes cheese made with fermentation-produced chymosin FPC, can it still be labelled certified organic? (280)
No. FPC is produced by fermentation processes using bacteria, fungi or yeast that have had bovine rennet-producing genes inserted into them. This means FPC is a product of genetic engineering, which is prohibited for use in organic production (1.4 a) and 3.27 of 32.310).

Collagen Casings

Is collagen casing allowed in the production of organic sausage? (105)
Yes. Collagen casings are acceptable for poultry sausages only. If derived from cattle must be guaranteed free of specified risk materials. Any other ingredients added during the manufacturing cannot be genetically engineered.(see “Collagen casing” PSL Table 6.4)


Use of desiccants

Can desiccants, such as silica gel pouches, be added to containers of organic spices? (439) - 19 Apr 2019
Yes. Silica desiccants including silica gel pouches may be used as silica is silicon dioxide and silicon dioxide is listed in 6.3 with no restriction. Because the silica gel packs will be in direct contact with food, they are expected to be food-grade as are packaging and other food-contact surfaces (32.310 8.1.1)



Can Dextrose be used as a flavouring agent in organic products? (236)
Yes. Organic dextrose may be used as a flavouring agent in organic production.


Carriers derived from a substance

When present in permitted substances, are carriers that are themselves "derived" from a substance subject to the requirements of 'Extraction solvents, carriers and precipitation aids' (PSL Table 6.3) (376)
Yes, carriers present in permitted substances are subject to the requirements of "Extraction solvents, carriers and precipitation aids" unless they are organic ingredients.


Gelatin – Alternatives

Are there acceptable alternatives to gelatin, such as seaweed and plant derived hypromellose? (118)
Plant substances such as seaweed extracts are acceptable alternatives to animal-derived gelatine. Hypromellose is a synthetic, non-agricultural substance and therefore cannot be used because it is not specifically included in the PSL.

Indirect Processing Aids

Can products not listed on the PSL be used as “indirect processing aids”?  (e.g. – mineral oil on cutter/slicer blades) (61)
Indirect processing aids aka “incidental additives” cannot compromise organic integrity. In short, agricultural products not on the PSL can only be used as processing aids if they are organic. Non-agricultural products must be on the PSL. (see 3.30, “incidental additive” and 8.1.2 in 32.310)


Which forms of lecithin are acceptable, according to the organic standard? (14)
Organic lecithin is preferred when used as an ingredient or as a processing aid. Non organic lecithin satisfying 32.310 1.4 a, may be used if the organic form is not commercially available.  If bleached the bleaching agent must be food grade hydrogen peroxide. (see “Lecithin” PSL 6.3 & 6.5)

Mineral Salts of Ascorbic Acid

Can the mineral salts of ascorbic acid (calcium ascorbate and sodium ascorbate) be used as food additives (Table 6.3)? (163)
No. Ascorbates are not the same substance as ascorbic acid, and therefore cannot be used.


Are nitrates forbidden in all processed foods? Is it possible to produce organic bacon? (56)
Nitrates such as those found in celery or chard extracts, juices or cultured powders may be used. Organic supplies must be used if commercially available. (see Meat Curing Agents PSL Table 6.3)

Can the ingredient "cultured celery powder" be used as a source of nitrite? (153)
Yes. Cultured celery powder is an acceptable source from which nitrites can be generated to cure organic meat. An organic supply must be used if commercially available. (see Meat Curing Agents in PSL Table 6.3)


Sodium citrate

If non-synthetic sodium citrate is not commercially available (or not available at all), can synthetic sodium citrate be used as a processing aid (table 6.3)? (405.1)
No. The annotation for sodium citrate in Table 6.3 does not include a commercial availability clause and clearly restricts the use to the non-synthetic form.

What type of manufacturing process would enable sodium citrate to be considered “non-synthetic” (and thus be compliant with PSL table 6.3)? (405.2)
Non-synthetic sodium citrates can be derived by biofermentation of some type of sugar, followed by filtration (physical) and separation by a non-chemical driven precipitation step. Sodium citrate could become prohibited if precipitated by a chemical agent even if the sugar and biofermenting agent are non GE. The synthetic / non-synthetic status of various substances is planned for review during the 2020 revision of the COS.
Note: the SIC answered this question from the perspective of sodium citrate being listed in Table 6.3 which is titled "Ingredients Classified as Food Additives". Sodium citrate would need to be listed in Table 6.5 to be used as a processing aid.



Can stevia be used as a sweetener in organic products? Is non-organic stevia admissible under the 5% non-organic ingredients rule? (171)
Stevia is a plant product which can be used in the manufacture of organic products. As stevia is commercially available in organic form, this form must be used.



Beyond non-organic rice or waxy maize starches, which are listed as permitted by the 'Starch' listing in Table 6.4, would starches made from other sources (i.e. tapioca, potatoes, arrowroot, cassava, etc.) have to be certified as organic? (433) - 19 Apr 2019
Yes. Unless the specific starch is listed in the PSL then certified organic varieties are required.


Vitamin D

Is the use of vitamin D allowed for fluid milk products if it contains a preservative not listed on the PSL? (137)
Yes. Vitamin D sources containing non-listed preservatives are allowed in organic fluid milk products as the addition of Vitamin D to milk is required by law and a commercial availability search element was not included in the 'Vitamin and mineral' annotation in Table 6.4 (refer to 6.2.3 of the PSL for insights into commercial availability search requirements). Keep in mind GE rules regarding the inclusion of substrates as outlined in 6.2.1 (32.311) do have to be addressed.


Substrate for probiotics

Can a non-organic agricultural substance such as whey be used as the growing media to manufacture probiotics used as a feed supplement or as an ingredient for food? (252)
It depends. Non-organic agricultural ingredients such as whey, can be used as the growth media or substrate to manufacture probiotics used as a feed supplement or as an ingredient for food, as long as their use complies with the requirements of 32.311 5.1.2 and 6.2.1, as follows:

a) if the probiotic includes the substrates or growth media, the substrate or growth media ingredients shall be listed in PSL tables 5.2 (feed), 6.3 or 6.4 (food). If listed in the PSL, any use of non-organic agricultural substances listed in the PSL must comply with substance listing annotations;

b) if the probiotic does not include the substrates or growth media, it shall be produced on non-genetically engineered substrates or growth media, if commercially available.

This means each substrate needs to be assessed individually for compliance. For example, whey residues are not permitted in a probiotic product because whey is not listed in the required tables. Probiotic products without whey residues are permitted without a commercially available search because at present there is no milk being produced from genetically engineered animals.


Ingredients used for micro-organism preparation

Are the requirements of 6.2.1 of the PSL applicable to “ingredients used for micro-organism preparation” (see 'Micro-organisms' listing in Table 6.4) if the micro-organisms preparation does not include the substrate? (375.1)
Yes, no matter if the micro-organism preparation includes the substrate or not, the requirements of 6.2.1 apply to each ingredient produced using substrates or growing media that is a component of a micro-organism preparation (see 9.1.2).

Can the micro-organisms product include synthetic preservatives? (375.2)

Micro-organism preparations cannot contain synthetic preservatives (see 1.4 j).


Metabisulphite in alcohol production

Is potassium metabisulphite allowed in alcohol production? (348)
Yes. It is listed in the PSL (table 6.3) for use as a preservative in alcoholic beverages (as an alternative to SO2). Minimal use of either sulphite form is recommended, and the "maximum allowable levels" as listed in the "Anhydrous sulphur dioxide, sulphurous acid (sulphur dioxide, SO2)" PSL annotation should be followed.


Use of calcium chloride in beer making

May calcium chloride be used as an ingredient in beer making? (482) (April 29, 2020)
No. Calcium chloride as an ingredient is restricted to milk, fat, soybean and fruit and vegetable products. (see Table 6.3, Calcium chloride). However, water as an ingredient is outside the scope of the standard, if calcium chloride is used as a water treatment - before the water enters the production stream, it would be permitted.


Amidated, low-methoxyl pectin

Do food products containing amidated, low-methoxyl pectin qualify for use in products with ≥95% or 70-95% organic content? (357)
Yes, amidated versions are permitted as there are no constraints in the annotation for pectin in Table 6.3.


Cleaners, disinfectants and sanitizer

Conformity of a cleaning product

Manufacturers of concentrated sanitation products may provide Safety Data Sheets (SDSs) showing the ingredients of both the concentrated form and the diluted form (as used) on the same document, or they may provide two distinct SDSs - one specific to the concentrated form and another specific to the diluted (as used) form. Which SDS should be used to evaluate the conformity of a cleaning product to the PSL if the ingredient listings are different? (437) - 19 Apr 2019
If the operation is using a diluted version, either purchased or diluted on site, the SDS for the diluted product is used for the evaluation compliance process.


Chlorine to disinfect poultry carcasses

Can chlorine be used to disinfect livestock carcasses? Are there alternative substances or processes? (254) (476) - 18 August 2020
Yes. Livestock, including poultry, carcasses, may be disinfected with peracetic acid (Table 7.3) or chlorinated water, provided the concentration of chlorine does not exceed the maximum limits applicable under regulations for safe drinking water. See Table 7.3 - Chlorine compounds. As an alternative peracetic acid can be used at disinfecting rates (Table 7.3). Alternative physical processes such as steam, hot water or High Pressure Processing (HPP) are allowed.


Assessment of detergent biodegradability

Does each component (e.g. surfactant, chelating agent, enzyme, and dispersant) of a detergent need to be assessed individually for its biodegradability? (444) - 21 June 2019
No. The purchased "detergent" product must be rated as biodegradable.


Substances for egg cleaning

Can substances listed in Table 7.4, with a removal event, be used to clean eggs? Is potable water required to wash eggs? (351)
Only substances listed in Table 7.3 as permitted for direct contact with organic product may be used to clean eggs. Water used for egg washing must be potable. See CFIA 'Shell Egg Manual' requirements. Take note however that organic vegetable oils, or other appropriate non-organic processing aids in PSL Tables 6.5 such as, e.g. silicon dioxide, could be used as defoaming agents during egg washing.


Alternatives to Table 7.3 and 7.4

In a facility where both non-organic and organic food is processed, can cleaners not listed in 7.3 or 7.4 be used immediately prior to the processing of the organic product? (91)
Yes – However, the use of cleaners not listed in tables 7.3 or 7.4 (PSL) is permitted under specific conditions laid out in 8.2.3 (32.310): 1) the efficacy of the alternative cleaning substance is documented ; 2) the cleaning materials used are effectively removed from the product contact surfaces, by an acceptable removal event (see 3.59 “removal event” definition) and that process documented; 4) the disposal of the effluent has been neutralized to minimize the environmental impact.

Non-food Contact Surface Cleaning

Do clauses 7.3 and 7.4 apply to the cleaning of: dedicated and non dedicated spraying equipment; of irrigation systems; and non-food contact surfaces such as floors, windows, staff toilets etc.? (21.1) (10)
Tables 7.3 and 7.4 of the Permitted Substances Lists generally apply to product (7.3) and product contact surfaces (7.3 and 7.4). While the cleaners listed in these tables may be used in other applications, and are preferred, cleaning of non-product  contact surfaces is not restricted to these cleaners. In the case of use of substances not listed in 7.3 & 7.4, the operator is responsible to ensure that no residual contamination occurs on land and crops.

Substances used as cleaners

Can substances listed as food additives (PSL 6.3) or processing aids (PSL 6.5), such as tartaric acid, be used as cleaners in facilities where organic product preparation takes place? (319)
If substances listed in 32.311 7.3 & 7.4 have been shown to be ineffective, substances listed in Tables 6.3 and 6.5, such as tartaric acid, or any other non-listed substance, can be used to clean organic product contact surfaces in facilities where organic product preparation occurs, as per criteria stated in 310 8.2.3.


Botanical compounds as cleaners

Can botanical compounds, such as essential oils, be used to clean organic products or organic product contact surfaces? (366)
Botanical compounds such as essential oils cannot be used to clean organic products because they are not listed in 32.311 Table 7.3. Botanical compounds such as essential oils may be used to clean organic product contact surfaces in accordance with 32.310 8.2.3, or if used as wetting agents (see 32.311 Table 7.4 Wetting agents).


Annotation for surfactants and wetting agents

Can you clarify whether the annotation in "surfactants' and 'wetting agents" means that the user needs to document that the substance complies with the Detergents listing in 7.4 AND the Soaps listing in 7.4, or simply either one of them? (345)
The annotation 'See Table 7.4 Detergents; Soaps.' should be read with an "or" (soaps OR detergents). The nature of the product in which the surfactant or the wetting agent is an ingredient will determine which listing to use.


Surfactant, spreaders, stabilizers, foaming agents

Must formulants, such as surfactant, spreaders, stabilizers, foaming agents, contained in commercial cleaning products be listed on 7.3 and 7.4, or only the active ingredients?? (453) - 26 Sep 2019
When commercial cleaning products are used without a removal event on direct contact or on contact surfaces with organic products, all the ingredients listed on the Safety Data Sheets (SDS) and the cleaning product label, including any formulants, must be listed in PSL Table 7.3 or be chemicals used to treat drinking water, or serve as product stabilizers. When used on product contact surfaces followed by a removal event, only the ingredients on the SDS, including formulants, must be listed in Table 7.3 and/or 7.4.


Cleaning of dairy equipment

Is sodium phosphate tribasic dodecahydrate permitted for use as a cleaner, disinfectant and sanitizer on dairy equipment as a derivative of phosphoric acid? (493) - 18 August 2020
No. Cleaning substances, including derivatives, must be listed in Tables 7.3 or 7.4. (7.1.3 in CAN/CGSB-32.311, SIC Final Questions and answers -Q&A 453) unless the derogation in 8.2.3 of CAN/CGSB-32.310 is pertinent.


Colloidal silver

Can colloidal silver be used as a cleaning product for food contact surfaces? (274)
Use of colloidal silver as a cleaning product must comply with 8.2.3 and 1.4 of 32.310.


Neem oil and diatomaceous earth

Can neem oil and diatomaceous earth (listed in table 8.2) be permitted in direct contact with organic food products? (310)
Yes. While the title of 8.2 is "facility pest management substances", there is no restriction on the use of diatomaceous earth, carbon dioxide or neem oil in relation to food contact post-harvest.


Peracetic Acid

Peracetic Acid (peroxyacetic acid) is listed on table 7.3 PSL. Are all forms of this substance allowed, regardless of method of production? (221)
Yes. There are no restrictions on the method of production in the annotation for peracetic acid


Peracetic acid containing synthetic acetic acid

Is peracetic acid that contains synthetic acetic acid permitted? (390)
Yes. Commercially, peracetic acid is produced by reacting synthetic acetic acid and hydrogen peroxide and residues of both reactants will more than likely be present. As there is no restriction in the peracetic annotation in PSL Table 7.3, peracetic acid products containing residual amounts of hydrogen peroxide and acetic acid are permitted for use in direct contact with organic products without a removal event


Electrolysed water

Question under review

Is electrolysed water allowed by the Canada Organic Standards? (290) (491) 18 August 2020
Electrolysed water (which may contain hypochlorous acid as a byproduct of either electrolysis or from the dissolution of chlorine compounds in water), is permitted for all production types except maple syrup. For maple syrup refer to 7.2 of CAN/CGSB-32.310.


Use of detergents to wash clothing of employees

Must laundry detergents used to wash clothing of employees comply with the Canadian Organic Standards when they work in an operation manufacturing organic products? (489) 18 August 2020
When clothing is in direct contact with organic food intentionally (i.e. fabric gloves), laundry detergents must comply with clause 8.2 of CAN/CGSB-32.310. Otherwise, the clothing is not considered a food contact surface, and is outside the scope of the standard.


Use of piperonyl butoxide

Are pyrethrin products containing piperonyl butoxide as a synergist permitted for use in organic facility pest management programs? The annotation in 8.2 of CAN/CGSB-32.311 specifically prohibits piperonyl butoxide as a carrier. (490) - August 18 2020
No. The annotation for pyrethrin is to prohibit its use if it contains piperonyl butoxide. When used as a synergist, piperonyl butoxide is considered an active ingredient under the Pest Management Regulatory Agency and would need to be listed in CAN/CGSB-32.311 to be acceptable in organic production.

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