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 referred to in the Final Questions and Answers are those of CAN/CGSB-32.310, General Principles and Management Standards, unless otherwise specified.
COR – Canada Organic Regime
CB – Certification Body
GE – genetically engineered
COS – Canadian Organic Standards
CAN/CGSB-32.311 – Permitted Substances Lists
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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 Clause 5.1.7? (6)
The intent of Clause 5.1.7 is to prevent deliberate alternation without just cause. In 2026 Canadian Organic Standards, the Clause 5.1.8 allows temporary alternation with justification, with prior notification to the certification body (CB); and upon prior approval based on an action plan as described in Clause 5.1.8 a).
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 products? (97)
In the event that the operator has no crops to sell, and wishes to allow certification to lapse, an application to recertify would have to be done in compliance with requirements of the Safe Food for Canadians Regulations as they apply to new operations.
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 Clauses 5.1.3 and 5.1.4? (488)
If the non-organic operation is a separate legal entity, then it is not subject to organic transition certification requirements in Clauses 5.1.3 and 5.1.4. But if the non-organic operation is not a separate legal entity, Clauses 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 Canada Organic Regime operating manual.
Buffers #
How should the minimum buffer zone be measured in an orchard? (138.1)
The distance is measured from drip line (the edge of the tree canopy) to drip line between an organic orchard and adjacent non-organic orchard. If a portion of the organic trees are within the buffer zone, the entire harvest from the affected trees must be 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. Clause 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 8 m or wider buffer (Clause 5.2.2 a)) or other effective barriers (Clause 5.2.2 b)) must be employed. For isolation distances relevant to GE crops, refer to Clause 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.
External buffer zone #
Can a buffer zone be established on land not owned by the operation? (499.1)
Yes. The buffer zone is measured from the edge of the area treated with a prohibited substance to the edge of the organic crop, regardless of the entity owning/managing the land in the buffer zone, but the Certificatino Body must be able to verify compliance of such a buffer.
Buffer zone – immature hedgerow #
Does a newly planted, immature hedgerow eliminate the requirement for an 8m buffer zone? (499.2)
No. When a risk of contamination is present, this new planting is insufficient, and an 8 m buffer zone will need to put in place until the hedgerow fills in. An effective physical barrier does not have to be 8 metres wide.
Parallel production #
Is it parallel production if the same type production is separated by time? (73)
No. The growing of visually indistinguishable crops (organic and non-organic) non-simultaneously does not constitute parallel production. See definition of “parallel production” in Clause 3.
Can parallel production be allowed if management to avoid co-mingling is documented? (1)
Clause 5.1.4 prohibits parallel production of visually indistinguishable crops inside the same operation. Some exemptions do exist with conditions. Refer to Clauses 5.1.4 a) and d) and 5.1.5 for further details. Post harvest operations are not subject to this prohibition.
Is the word ‘simultaneous’ in the definition of “parallel production” in Clause 3 applicable to fields that are isolated from other fields and managed by the same operation? (450.1)
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 or isolation of the fields.
Clause 5.1.4 states that parallel production is an exception to an enterprise’s entire transition to organic. The definition of an “operation” states that an operation may have multiple production units but “enterprise” is not defined in the Standards. What is the difference between enterprise and operation? (450.2)
Enterprise and operation are synonymous.
Does the term “farm, company or organization” included within the definition of an operation encompasses 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)
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 Canada Organic Regime Operating Manual)
Parallel production after harvest #
Do organic and conventional crops need to be visually distinguishable while in the field, or only once harvested such as organic corn grown for grain and conventional corn grown for silage? (552)
Organic and conventional crops only need to be visually distinguishable after harvest to not be considered parallel production.
Parallel production & hydroponics #
Can an operator engage in hydroponic production (not organic) and produce the same products using organic methods? (261)
No. Clause 5.1.4 does not allow parallel production of visually indistinguishable products of annual crops, regardless of the non-organic method of production.
Transition – Management change #
In the case where there is a change in management, is a transition period necessary? (58)
No. A change in management or control by a new owner/operator/manager of an organic operation does not require a transition period.
Transition – Adding new fields #
Does the requirement, in Clause 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 operation? (8)
If it can be verified that no prohibited substances have been applied for the past 36-months, no transition period is required for new fields added to for existing operations holding organic certification (Clause 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)
The 36-month transition period is calculated from the date on which the growth of the GE crop is terminated (e.g., by harvest, tillage, plowing) as per Clause 5.1.1.
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)
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. But new operations must apply for certification 15 months in advance of when they want to market products as organic to allow for the certification body’s oversight during the last 12 months of transition.
Status of crops grown after first application #
Can crops grown during the season of the first inspection of a new COR applicant be stored and sold as organic in the following year after the client receives certification? (570)
No. Per Clause 5.1.1, the standard needs to be fully applied (after application) for 12 months on the production unit before the first harvest. Therefore, only crops seen at the second inspection may be eligible for certification.
Type of plant grown in containers #
Can any type of plant, including perennials, be grown in containers or any off-ground structure (e.g., elevated gutters) and be compliant? (396)
Yes. Plants, including perennials, can be grown in containers or any off-ground structure in a greenhouse or outside if the requirements in Clause 7.5 are respected, including container soil composition and volume (Clauses 7.5.5.1 to 7.5.5.4).
Non-organic trees or grapevines planted before end of transition #
If non-organic trees or grapevines (perennial transplants) are planted before the land has completed the 36-month transition, how long before the fruit would qualify as “organic”? (431)
The fruit would qualify as organic either after the completion of the 36-month transition period (Clause 5.1.1), or 12 months after the planting date (Clause 5.3.6 f)) – 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 protect crops from cross-pollination with GE crops. Shorter distances other than those provided in the Note 5.2.2 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. 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) #
In the note in Clause 5.2.2 d), does “(for seed production)” refer to the organic alfalfa or to the GE alfalfa? (282.1)
The note refers to the production of organic alfalfa seeds.
Corn field surrounded by GE corn #
My sweet corn field is surrounded by GE corn. I do multiple plantings, and ensure buffer zones are in place but I think there may be times when pollen from the GE corn contaminates my crop. Can this crop still be compliant in light of the GE risk management criteria in Clauses 4.4.6 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 or contamination by a pesticide applied in a government-sponsored pest control program? (67, 69)
The standard requires a 36-month transition after the application of a prohibited substance (Clause 5.1.1). Buffer strips around the contaminated zone and a transition period would be required before the contaminated area could be eligible for organic production (refer to Clause 5.2.2).
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, a 36-month transition would not be needed if the seeds are untreated and removed prior to germination. If the seeds are treated with prohibited substances and/or if the seeds germinate, the area where the dumping occurred must go through a 36-month transition while maintaining an 8-metre buffer around the contaminated area (Clauses 5.1.1 and 5.2.2).
If GE seeds are accidentally planted in an organic system, is a 36-month transition required? (313.2)
Yes. GE seeds are prohibited (Clause 1.4); therefore, fields contaminated with GE seeds require a 36-month transition to return to organic status. Any GE plants that have sprouted must be destroyed 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 terminated (e.g., tilled, ploughed) as per Clause 5.1.1.
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)
This scenario would be an intentional violation of Clause 5.1.7 of CAN/CGSB-32.310 that prohibits alternating in and out of organic production management. Therefore, the 36-month transition period is irrelevant and does not apply. The production unit may not be eligible for organic status for at least five years (including a 36-month transition period) per Clause 5.1.8
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 equipment must be well maintained to minimize potential contamination of land (Clause 5.2.1).
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)
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 products or land is prevented. The operator must document the cleaning process (See Clause 5.2.1).
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 cannot come in contact with organic land or crops. If the irrigation system can be shown to be free of such residues, it may be used to irrigate organic farms (see Clause 5.7).
Treated posts #
Would dipping untreated wooden posts in paraffin wax or using a polyethylene sleeve be allowed under Clause 5.2.3? (186)
Yes. Paraffin or polyethylene coverings can be used as protective sleeves (Clause 5.2.3 a)).
Certification of plantations – culinary oils #
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 Clause 3 as “plants collected or harvested in their natural habitat.”
Protection and promotion of ecosystem health #
Are operators required to have management practices and features to promote and protect ecosystem health on their own operations when adjacent lands and territory have such measures or features? (542)
Yes. These measures and features are required to be incorporated into the production system on every organic operation per Clauses 1.2 & 5.2.4.
5.3 Seeds and planting stock #
Organic seed search #
Is an organic seed search necessary if non-organic seed is carried over in inventory? (619)
No. An organic seed search is not necessary if a documented search was conducted and verified by the certification body at the time of purchase of the non-organic seed.
Planting stock for sweet potato #
When sourcing planting stock for sweet potato production, and considering they are classified as perennial, what requirements need to be fulfilled? (554)
Sweet potatoes may be perennial in a sub-tropical setting, but in the North American climate, sweet potatoes do not produce a crop beyond the first season; therefore they are not perennial as per the definition of “perennial crop” in Clause 3, and they shall be considered an annual crop. Seedlings would need to be organic as per Clause 5.3.1. Non-organic cuttings (planting stock) are permitted if organic cuttings are not commercially available (per Clause 5.3.5), and may be treated with substances listed in CAN/CGSB-32.311 Tables 4.2 or 7.3 as per Clause 5.3.5 c).
Seed – Buffers #
Can seeds produced on buffer strips be planted in organic fields? (17.1)
Seed produced on the operation’s buffer zones (or transitional land) may only be planted within the same operation provided the buffer zone is managed by the operation (see Clause 5.3.4). This seed may be used without a commercial search for organic seed.
Seed – Common #
Can non-organic common seeds be used if organic common seeds are not available? (17.2)
Yes. “Common” seed could be considered a varietal distinction subject to the exceptions for the use of non-organic seeds and when organic “common” seed is not commercially available as per Clause 5.3.5. See the definition of “commercially available” in Clause 3.
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)
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 Clause 5.3. They must be organic unless the specific exceptions listed in Clause 5.3.5 apply.
Seeds – GMOs #
What level of GE contamination would be acceptable in seeds used for production under organic management? 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)
When purchasing seed for organic production, non-organic seed which is non-GE and free of prohibited substances can only be used when organic seeds are not available and a documented search, involving potential known organic suppliers, has been conducted (Clauses 1.4, 1.5 & 5.3.6 b)).
Operations growing crops that have a greater potential for GE contamination have the responsibility to mitigate this risk (Clause 5.2.2 d)) to the best of their ability, as outlined in their GE risk management plan (Clause 4.4.6). Testing for GE contamination prior to seeding and/or selling these high-risk crops may be part of this risk mitigation plan
Mutagenesis -cisgenesis #
Do seeds resulting from mutagenesis or cisgenesis fall within the Standard’s prohibition of genetic engineering? (255)
Mutagenesis and cisgenesis by way of genetic engineering are prohibited by the Standard (Clause 3). The use of these techniques is limited to producing plant materials through traditional breeding techniques.
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 Clause 5.3), at what stage would the resulting plant or transplant be considered organic and can be sold as such? (475)
When the potted plant or transplant (propagated from non-organic planting stock) is intended for the retail marketplace to be purchased for non-commercial purposes, it will not be considered organic until 12 months under organic management. When intended for commercial use as an input to organic crop production, the plant or transplant may be considered organic in a shorter period of time.
Seed – Transitional fields #
Can seed grown on transitional land qualify as organic seeds/tubers (Clause 5.3) if used on the same operation where it was produced? (113)
Yes. As of 2026 Canadian Organic Standards, Clause 5.3.4 permits the use of seed or planting stock from transitional production units within the same operation.
Use of GE seeds before transition #
Can prohibited substances, including GE seeds, be used by an operator in fields not yet in the 36-month transition period? (468)
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 crops on the operation. Take note that in the case of GE crops, calculation of the transition period begins after crop termination per Clause 5.1.1.
Seed – Treatments #
Can a bleach solution be used on organic seeds? On non-organic seeds? (77)
A bleach solution containing a concentration of chlorine higher than municipal drinking water (see CAN/CGSB-32.311 Table 7.3 Chlorine compounds) cannot be used on organic seeds to either clean or treat them prior to use. However, disinfection of Solanaceae seed with a 2.5% sodium hypochlorite solution is permitted under Seed treatments in Table 4.2. 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 seeds.
Organic percentage for seeds #
Do seed coatings or treatments need to be considered when calculating the organic percentage of an organic seed product? (472)
No. Seed, as defined in the Seeds Act, is not food and coatings or treatments are not food ingredients; therefore Clause 9.2 does not apply and the calculation of the percentage of organic ingredients is not applicable. Seed products need to be 100% organic seed and any coating or treatment must be listed in Table 4.2 (Column 1 or 2) or Table 7.3 of CAN/CGSB-32.311 as per Clause 9.1.3 e)).
Tissue culture #
Are propagules produced through plant tissue culture micropropagation included within the provisions of Clause 5.3 requiring that they be produced in accordance with the standard? (203)
Yes. Clause 5.3 applies to propagules produced through plant tissue culture micropropagation. Substrates shall comply with Clause 1.4 a) per Clause 5.3.7 c).
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.
Perennial crops managed as annual crops #
If a producer manages a perennial crop (such as strawberries) as an annual (harvest within 12 months of planting) from seedlings, do the seedlings have to be organic? (641)
Yes. As of COS 2026, when the first harvest (less than 12 months from planting) is to be considered organic, the strawberry seedlings must be organic as per Clause 5.3.6 e). Operators have until 2030 to adjust to this requirement.
5.4 Soil fertility and crop nutrient management #
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)
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.
Hydroponics #
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 Clauses 5.4 (Soil fertility and nutrient management) and 7.5.5 (prohibition of hydroponic).
Manure management #
Manure sources #
Can manure from livestock raised in cages be used, if the farm has a nutritional deficit and no other source of manure within a reasonable distance? (83)
As per Clause 5.5.1.1 a), 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 Clause 5.5.1.1 a). This is the intent of the standard. The wording of Clause 5.5.1.1 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 Clause 5.5.2.5? (31, 159)
Clause 5.5.2.5 does not apply to incidental animal droppings such as those from wild animals or birds, grazing or working animals; however, Clause 5.5.2.4 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. Clause 5.5.2.6 clearly states that, 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 edible crop.
Manure from non-organic animals raised on an organic operation #
Clause 5.5.1 states that “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 farms? (438)
Yes. Animal manure, whether from organic animals or not, produced on the 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.
Manure from confined operations #
Can manure from confined animal feeding operations be applied on organic land? (322)
Yes. Manure from such operations may be used providing requirements of 5.5.1 and 5.5.2 are met.
