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.
CB – Certification Body
CFIA – Canadian Food Inspection Agency
COS – Canadian Organic Standards
CAN/CGSB-32.311 – Permitted Substances Lists
GE – genetically engineered
Identification of organic products in storage #
Are signs identifying organic products as organic required on a storage unit if non-organic products also in storage are not GE? (620)
Signs stating “organic” are not required on storage units; however unique lot codes are required as outlined in Clause 4.4.1. Maintaining the integrity and identity of organic product is essential, especially when a production unit handles both organic and non-organic products (per Clause 8.1.5 b)).
Staff training #
Are CBs 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)
CBs are required to verify compliance with the standard. If in the course of inspecting a facility, it becomes apparent that the staff responsible for maintaining organic integrity lack the necessary training, this could be the basis of a report of non-compliance. See Clause 4..
Irradiation (X-rays, ultraviolet radiation, microwave) #
Can ultraviolet radiation be used on all organic products? What about packaging? (152, 338, 419)
As of the 2026 COS, ultraviolet (UV) rays classified as “non-ionizing radiation” (see the definition in CAN/CGSB-32.310 Clause 3) are permitted more broadly, but with a few continued restrictions. UV may be used to address pest loads on all organic product and product contact surfaces including equipment, packaging and empty bee hives (see Non-ionizing radiation, in CAN/CGSB-32.311 Table 7.3). However, ultraviolet rays cannot be used to boil (Clause 7.2.14) or sterilize (Clause 7.2.12.2) tree sap, such as maple or birch. Ionizing radiation continues to be prohibited per Clause 1.4 c).
X-Rays for inspection purposes #
Is the use of x-rays permitted for inspection purposes, such as detection of foreign materials, during the preparation of organic products? (556)
Yes, providing it is for inspection purposes only, and does not reach levels of irradiation treatment prohibited by Clause 1.4 c). See the definition for “radiation, ionizing” Clause 3.
UV-C light use in product preparation and handling #
Can UV-C light be used to treat organic products, such as frozen foods, during preparation and handling? (560)
Yes, ultraviolet light is considered non-ionizing (see Clause 3 definition of “radiation, non-ionizing”) and can be used to manage pest loads on product and product contact surfaces (CAN/CGSB-32.311 Table 7.3).
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)
The resulting water is acceptable if it falls within Health Canada’s Guidelines for Drinking Water and no prohibited substances have been added to the water nor prohibited processes have been used as part of the filtration process.
8.2 Cleaning, disinfecting and sanitizing #
Water – Product preparation and vegetable rinsing #
What are the requirements for the quality of water used to wash organic vegetables or prepare organic products? (128, 5)
Water meeting CFIA’s potable standards is required. Water must meet the requirements for potability as per local, provincial or federal authorities. When water is in contact with an organic product, the chlorine concentration must not exceed the levels permitted in municipal drinking water systems and rinsing is not required.(CAN/CGSB-32.311 Table 7.3). Higher concentrations followed by a rinse remain prohibited.
Cleaners – Milking equipment #
What is the distinction between acceptable cleaning agents for milking equipment on farms vs. those used in processing facilities? (209)
Clause 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 Clause 8.2.
8.3 Facility pest management and post‐harvest management #
Pest control – Bait station location #
When a pesticide not listed in CAN/CGSB-32.311 is used in a baited station clamped to the inside wall of a facility preparing or storing organic products, is having it in the bait station sufficient to satisfy Clause 8.3.3 requirement? (38)
No. Only pesticides listed in CAN/CGSB-32.311Table 8.2 may be used in the interior of a facility where organic products or packaging materials are processed or stored (Clause 8.3.5 b) 2). This applies even if the substance is contained within a bait station and there is no potential contact between the pesticide and the organic products or packaging.
Pest management – indoor/outdoor #
Does 8.3.3 apply to pest control substances used inside facilities or to those used on the exterior? (212)
Wherever they are located, crops, ingredients, finished goods, and packaging cannot be exposed to non-listed pest control substances permitted by Clause 8.3.5.
Pest control used around farm buildings and on-farm storage areas shall not compromise the organic integrity of the surrounding farm environment. Non-listed substances, permitted by Clause 8.3.5, cannot be used on the exterior of buildings located on farmland.
Conversely, compliance assessment is not required for non-listed pest control substances permitted by Clause 8.3.5 around facilities that are not located on farmland, as there is no risk to organic integrity.
Pest control in food processing facilities #
Clause 8.3.2 states that substances listed in Table 8.2 of CAN/CGSB-32.311 can be used in food processing facilities to control pests. Can substances listed in CAN/CGSB-32.311 Table 4.2 (column 2) (e.g. pheromones, sodium tetraborate) also be used? (392)
No. Only substances in CAN/CGSB-32.311 Table 8.2 can be used to control pests in food processing facilities. Substances in CAN/CGSB-32.311 Table 4.2 (column 2) are strictly for crop production. Please refer to Clause 8.3.5 for alternative pest control options for food processing facilities.
