This section of the Final Questions and Answers complies with Canadian Organic Standards 2026 #
To consult the QAs complying with the 2020 COS, click here.
The clauses and tables referred to in the Final Questions and Answers are those of CAN/CGSB-32.311, Permitted substances lists, unless otherwise specified.
CAN/CGSB-32.310 – General principles and management standards
CB – Certification Body
CFIA – Canadian Food Inspection Agency
COR – Canada Organic Regime
COS – Canadian Organic Standards
SFCR – Safe Food for Canadians Regulations
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 CAN/CGSB-32.311 if the ingredient listings are different? (437, 539)
If using a diluted version, either purchased or diluted on-site, the SDS pertaining to the diluted substance applies. In the event that no SDS was issued for the diluted version, the SDS of the concentrate applies. Further, if used without a removal event, the label of the concentrated product is referred to for both the concentrated and diluted version (Clause 7.1.3).
Chlorine to disinfect poultry carcasses #
Can chlorine be used to disinfect livestock carcasses? Are there alternative substances or processes? (254, 476)
Yes. Livestock, including poultry, carcasses, may be disinfected with 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.
*Water quality falls under the jurisdiction of provincial and territorial governments. Health Canada’s Guidelines for Canadian Drinking Water Quality indicates “Free chlorine concentrations in most Canadian drinking water distribution systems range from 0.04 to 2.0 mg/L”. The US Centers for Disease Control and Prevention (CDC) state “chlorine levels up to 4mg/L (4ppm) are considered safe in drinking water”.
Detergent as a cleaner #
Is a detergent considered a cleaner under clauses 7.1.2 and 7.1.3 of CAN/CGSB-32.311? What differentiates a detergent from a cleaner? (558)
As per Clause 7.1.1, any substance used to remove dirt, filth and foreign matter from organic products and organic product contact surfaces is a cleaner. A cleaner is only a detergent if specifically formulated for cleaning through the process of detergency as defined by ISO 862:1984(en) – Surface active agents https://www.iso.org/obp/ui/#iso:std:iso:862:ed-1:v1:en. Detergency is the result of the action of several physico-chemical phenomena and a detergent is a combination of many components including surfactant, chelating agent, enzyme, and dispersant.
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)
No, if the purchased “detergent” product is rated as biodegradable.
On the contrary, if the “detergent” product is not rated as biodegradable, any components that are not listed in Table 7.3 or 7.4 and surfactants need to be assessed as biodegradable. See Table 7.4 – Detergents
Is the manufacturer of a detergent required to test the biodegradability of its product based on the definition of “biodegradable” in clause 3 of CAN/CGSB 32.310? (515.1)
No. The definition of “biodegradable” applies specifically to inputs and production aids in crop and livestock production. For detergents (or surfactants), biodegradability shall be assessed based on OECD definitions and standards. See Detergents (or Surfactants), Table 7.4. Therefore, the manufacturer shall demonstrate that the biodegradability of the detergent meets or exceeds the guidelines defined by the OECD when assessing conformity.
Can a so-called biodegradable detergent contain non-listed or restricted substances such as phosphoric acid, whose use is only permitted for dairy equipment? (515.2)
Yes. If the detergent meets the biodegradability requirement as outlined in Table 7.4, there are no other restrictions.
Elimination of a detergent #
Regarding the annotation for the Detergents listing in Table 7.4, how can you determine that a detergent is “readily eliminated during wastewater treatment such that harm to the environment is minimized”? (559)
The annotation is not about the quality of the detergent or the manufacturer’s ability to demonstrate that it is “readily eliminated.” This annotation requires that wastewater treatment be in place to eliminate potential environmental harm when a non biodegradable detergent is used.
Anti-stick film after rinsing #
Is a detergent used on organic product contact surfaces that leaves an anti-stick film after rinsing permitted? (596)
Yes, if the remaining anti-stick substance is listed in Tables 6.3, 6.4 or 6.5 per Clause 8.1.2 c) of CAN/CGSB-32.310.
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 products may be used to clean eggs. Take note, however, that organic vegetable oils, or other appropriate non-organic processing aids in Table 6.5 such as silicon dioxide, could be used as defoaming agents during egg washing. Water used for egg washing must be potable. See CFIA ‘Shell Egg Manual’ requirements.
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)
Table 7.3 generally applies to organic products (7.3) and Table 7.4 applies to product contact surfaces. Compliance to Tables 7.3 and 7.4 is not required for other uses unless specified in the corresponding section of the standards. The operator shall ensure that no residual contamination occurs on land and crops as per CAN/CGSB 32.310 – 5.2.1 b) (equipment) and 5.7 (irrigation).
Substances used as cleaners #
Can substances listed as food additives (Table 6.3) or processing aids (Table 6.5), such as tartaric acid, be used as cleaners in facilities where organic product preparation takes place? (319)
If substances listed in Tables 7.3 and 7.4 have been shown to be ineffective, substances listed in Tables 6.3 and 6.5, 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 Clause 8.2.3 of CAN/CGSB-32.310.
Botanical compounds as cleaners #
Can essential oils be used to clean organic products or organic product contact surfaces? (366)
Essential oils compliant to the restrictions described in the Essential oils listing in Table 7.4 may be used to clean surfaces in contact with organic products. They cannot be used to clean organic products as they are not listed in Table 7.3.
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, 610.1)
a) Without a removal event, all the non-organic ingredients listed on the Safety Data Sheets (SDS) must be listed on Table 7.3. All other active and non-active ingredients, including formulants, must be listed on Table 7.3 or be chemicals used to treat drinking water, or serve as product stabilizers. For example, HEDP listed on the SDS would not be allowed since it does not appear on Table 7.3, while it would be allowed if listed as a non-active ingredient on the label.
b) When used on product contact surfaces followed by a removal event, all the non-organic ingredients on the SDS, and active ingredients on the label, must be listed on Table 7.3 and/or 7.4.
If a cleaner/sanitizer SDS and label do not list ingredients, is the product allowed under Tables 7.3 and 7.4? (610.2)
No. Active and non-active ingredient lists are needed from the manufacturer to assess compliance to Table 7.3 for substances used without a removal event. An active ingredient list is needed from the manufacturer to assess compliance to Tables 7.3 and 7.4 when substances are used with a mandatory removal event.
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)
No. Cleaning substances, including derivatives, must be listed in Tables 7.3 or 7.4. (Clause 7.1.3, Final Question and answer 453) unless the derogation in Clause 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 Clause 8.2.3 of CAN/CGSB- 32.310.
Neem oil and diatomaceous earth #
Can neem oil (listed in Table 8.2) be permitted in direct contact with organic food products? (310)
Yes. While the title of Table 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. 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 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.
Electrolyzed water #
Is electrolyzed water allowed by the Canada Organic Standards? (290, 491) – 18 August 2020
Electrolyzed water is listed under Chlorine compounds, ‘c) hypochlorous acid generated via electrolyzed water’ on Tables 7.3 and 7.4.
Sanitizing in apple packing lines #
Can a calcium hypochlorite product containing additional components not included on Table 7.3: sodium chloride, calcium carbonate and calcium hydroxide, be used in apple packing lines? (513)
Yes. Calcium hypochlorite is listed on Table 7.3 for use in direct contact with food, and these three secondary ingredients – sodium chloride, calcium carbonate and calcium hydroxide – are permitted as they are used to treat drinking water as per Clause 7.1.3 (“Other non-organic ingredients … shall be limited …. to compounds used to treat drinking water”). Concentration of the calcium hypochlorite shall not exceed maximum levels for safe drinking water when in direct contact with organic products such as the apples.
*Water quality falls under the jurisdiction of provincial and territorial governments. Health Canada’s Guidelines for Canadian Drinking Water Quality indicates “Free chlorine concentrations in most Canadian drinking water distribution systems range from 0.04 to 2.0 mg/L”. The US Centers for Disease Control and Prevention (CDC) state “chlorine levels up to 4mg/L (4ppm) are considered safe in drinking water”.
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)
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)
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.
Mint oil as sprout inhibitor #
Clove oil is permitted as a post-harvest sprout inhibitor for potatoes (Table 8.3). Can other plant oils, such as mint oil, be used for this purpose? (514)
Yes. Oils from the Lamiaceae (mint family), Apiaceae/Umbelliferae (celery family) and Myrtaceae (clove family) may be used as post-harvest sprout inhibitors.
Use of unlisted substances #
If an organic product is treated under a mandatory government program (such as exports of potatoes to the US) with a pest control substance not listed under Table 8.2, does the organic product maintain organic status? (593)
No. The only exception provided to substances listed on Table 8.2 is described in Clause 8.3.3 of CAN/CGSB-32.310, which specifies that there shall be no risk to organic product status or integrity and that contact of organic products with unlisted substances was avoided. The treatment of an organic product with an unlisted substance would not comply with these requirements, as is also specified in Clauses 1.5 and 8.4.3 of CAN/CGSB -32.310.
