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Canadian Organic Standards
Final Questions & Answers

Permitted substances lists for preparation

Updated on April 29, 2024
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Anti-caking agents for grated cheese #

What anti-caking agents are listed in the PSL that can be used in grated organic cheese? (435, 235) – 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) – 17 February 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, Table 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.

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 organic waxes, e.g., organic carnauba or organic beeswax, are not commercially available and the coating is non-edible and completely peelable. See Waxes, PSL Table 6.5. The paraffin cannot contain synthetic colours, preservatives, bactericides or fungicides. Microcrystalline wax is prohibited.

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.

Chymosin #

For cheese production, can we use non-GE chymosin containing sodium benzoate? (151)

Non-GE chymosin extracted from conventional calf stomach linings is permitted, providing an organic source is not commercially available. See Enzymes, PSL, Tables 6.3 and 6.5. Additional requirements outlined in 6.2.1 of PSL must be addressed if the production of allowed chymosin products involves the use of substrates or growth media. When the sodium benzoate acts as a preservative for the chymosin, it is classified as a non-agricultural subpart having a functional effect on the ingredient but not on the final product, nor is it declared on the product label, it is permitted (9.1.2 of 310) as of the 2020 revision of the standard.

Use of desiccants #

Are silica gel pouches in containers of organic spices permitted? (439) – 19 Apr 2019

Yes. Silica desiccants, which includes silica gel pouches, may be used as silica, that is silicon dioxide, is listed in 6.5 with no restriction (except for maple products). Because the silica gel packs will be in direct contact with food, they are expected to be food grade as are packaging (8.1.6, 32.310) and other food-contact surfaces (8.1.1, 32.310)

Dextrose #

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 #

Can permitted substances contain carriers? (376)
As of the 2020 version of the standard, there is a separate “Carrier” listing with detailed restrictions as follows: “Carriers of non-agricultural origin may be used if listed on Tables 6.3, 6.4 or 6.5. Non-organic carriers of agricultural origin (such as wheat starch) may be used if ingredients or processing aids containing organic carriers are not commercially available”. See Carriers, Table 6.3, PSL.

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 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 Incidental additives, 3.35, “” and 8.1.2 in 32.310.

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.

Nitrates #

Are nitrates forbidden in all processed foods? Is it possible to produce organic bacon with culture celery powder? (56, 153)
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, Table 6.3, PSL.

Meat curing agent – Cherry extract #

Is cherry extract powder permitted as a meat curing agent? (534) 8 March, 2022

Yes, if the powder is organic. No, if it is not organic as the annotation for Meat curing agents (Table 6.3) does not indicate cherry.

Stevia #

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.

Starch #

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.


Sources of tocopherol in food preparation #

When preparing food products that legally require the addition of vitamins and minerals, does the annotation for ‘Tocopherols and mixed natural concentrates’ in Table 6.3 of the PSL apply? (564) (19 December, 2022)

No. If the vitamins and minerals are legally required (Table 6.4 of PSL), there is no other restriction to the source of Vitamin E (tocopherol) apart from being compliant with clauses 1.4 & 1.5 of CAN/CGSB-32.310 and clause 6.2.1 a) & b) CAN/CGSB-32.311 (if applicable). The annotation applies when tocopherols are added as antioxidants.


Requirements for agricultural ingredients #

Can non-organic skim milk powder be used as a minor agricultural ingredient in an organic food product, if the milk comes from cows fed with GE feed? (531.1) 8 March, 2022

Yes, provided organic skim milk powder is not commercially available. There are no requirements that animals be fed non-GE feed if the ingredient is non-organic.

Can a minor non-organic agricultural ingredient be fortified? (531.2) Yes, if legally required, such as fluid milk products, white flours, etc., or if legally permitted in non-dairy substitute products as per PSL 6.4 Vitamins and mineral nutrients. The ingredient and nutrients shall comply with prohibitions in 1.4 &1.5 (32.310) as per PSL 6.2.1, and with 9.2.1 d) & 9.2.2 a) (32.310).

Sub-parts of non-organic agricultural ingredients #

When non-organic agricultural ingredients contain food additives or ingredients not classified as food additives, do these sub-parts need to be listed in PSL Tables 6.3 or 6.4? (589.1) December 13, 2023

All sub-parts of the non-organic agricultural ingredient need to be assessed for compliance except processing aids if present (SIC Q&A 20.1).

Compliance of non-organic ingredients #

Can a prepared organic product contain the following non-organic ingredient: (589.2) 13 Dec 2023, 29 Apr 2024

a) dried fruit with added sulphites?

No, sulphites are prohibited per 1.5 f) (with one exception for alcohol production see Sulphur dioxide, anhydrous (SO2) listing PSL Table 6.3.)

b) tea extract extracted with a solvent not listed in 32.311?

Yes, providing that all sub-parts of the tea extract, except processing aids such as extractant solvents (SIC Q&A 20.1), are listed in PSL Table 6.3 or 6.5 per 1.5 f) (32.310), and conditions of 9.2.1.d) (95% organic content) or 9.2.2 a) (70-95% organic content) have been met.

c) alcohols (rhum, tequila, etc.)?

Yes, providing that all sub-parts, except processing aids (SIC Q&A 20.1), are listed in PSL Table 6.3 or 6.5 as per 1.5 f) (32.310), and conditions of 9.2.1.d) (95% organic content) or 9.2.2 a) (70-95% organic content) have been met.

d) sugar substitutes such as xylitol and erythritol?

No. These sweeteners are classified as food additives (Health Canada) and are not listed in PSL Table 6.3.

e) candy sparkles (containing multiple ingredients including colouring agents not from biological sources)?

No. All sub-parts including additives such as a colouring agent, except processing aids (SIC Q&A 20.1), must be listed in PSL Table 6.3 or 6.4.

fcured meat (ex. Bayonne ham)?

Yes, if cured and prepared without prohibited substances per 1.5 f) and all sub-parts, except processing aids (SIC Q&A 20.1), are listed in PSL Table 6.3 or 6.4 and conditions of 9.2.1.d) (95% organic content) or 9.2.2 a) (70-95% organic content) have been met.

g)  wild harvested herbs?

Yes, if prepared without prohibited substances listed in 1.5 f) and all sub-parts, except processing aids (SIC Q&A 20.1), are listed in PSL Table 6.3 or 6.4 (if applicable) and when conditions of 9.2.1.d) (95% organic content) or 9.2.2 a) (70-95% organic content) have been met.

 h) hydrogenated palm oil?

No. Hydrogenation modification (chemical reaction) of oil is not permitted. (32.310 8.1.3 & 9.1.1)

i) shellac

It depends on its use.

No, if the shellac is used as a glaze or coating for confections, fruit or vegetables. The shellac would then be used as a food additive or processing aid (Health Canada) and is not listed as such in PSL Table 6.3 or Table 6.4.

Yes, if the shellac is used as a colouring agent as per the annotation for Colouring agents in Table 6.3.


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. Keep in mind that GE rules regarding the inclusion of substrates as outlined in 6.2.1 (32.311) do have to be addressed.

Vitamins and minerals added to organic products #

Can vitamins and minerals be used to fortify organic products if not legally required? (500.1) – 18 Dec 2020
No. Organic products may not be voluntarily fortified with vitamins and minerals even if legally permitted. The only exceptions permitting voluntary fortification of organic products are a) dairy substitutes that are plant based, and b) fortification with ferrous sulfate when legally required or voluntarily if legally permitted. See Vitamins and mineral nutrients, PSL 6.4.

Do vitamins and minerals have to be certified organic to be used in organic products with 95% or above organic content? If yes, are commercial availability searches required? (500.2) – 18 Dec 2020
No. Vitamins and minerals are not agricultural products and hence are not certifiable to organic standards. Vitamins and Minerals used in organic products are ingredients classified as food additives and are listed in PSL 6.4. Per 9.2.1 a, ingredients classified as food additives are subject to substance listing annotations and restrictions specified in 6.2 of CAN/CGSB-32.311. As there are no organic commercial availability requirements listed in the annotation for Vitamins and Minerals in PSL 6.4, commercial availability is not applicable. However, there are restrictions in the listing annotations on when they may be used. See Vitamins and mineral nutrients, PSL 6.4.

Vitamins and minerals in supplemented foods #

Can vitamins and minerals be used in organic products categorised as Supplemented Foods, such as an energy drink? (612) 29 Apr 2024

No. Vitamins and minerals are permitted only if legally required or voluntarily added to non-dairy substitute products as listed in Table 6.4 32-311.

Substrate for probiotics #

Can a non-organic agricultural substance such as whey be used as the growing medium to manufacture probiotics used as an ingredient for food? (375.2)
Probiotics are covered by “Micro-organisms” in Table 6.4 and may contain residues of agricultural and biological substances as long as they are from non-genetically engineered sources (1.4 a). Probiotics may also contain non-agricultural subparts, such as carriers, or stabilizers that have a functional effect on the ingredient (the probiotic) but not on the final product in which the probiotic is being added (9.1.2 in 32.310).

Use of calcium chloride in beer making #

May calcium chloride be used as an ingredient in beer making? (482) – 29 April 2020
No. Calcium chloride as an ingredient is restricted to milk, fat, soybeans 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.

Yeast foods with DAP for alcoholic beverages #

Can yeast foods containing diammonium phosphate (DAP) be used in alcoholic beverages such as distilled spirits and other fermented products such as vinegar. (508) 24 March 2021
No. The annotation for Yeast foods in 32.311 Table 6.3 only permits the use of DAP in cider, mead and wine.

Preservatives for organic yeast #

If organic yeast is not commercially available can non-organic yeast products containing preservatives such as sorbitan monostearate be used? (457) 24 March 2021
Non-organic yeast may be used provided that all other prohibitions of 32.310 are met, including 9.1.2. 9.1.2 would allow the presence of sorbitan monostearate in the yeast product as long as the non-listed preservative does not have an effect on the final organic product, is not declared on the organic product label and is present only in insignificant amounts.

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.

Vegetable cooking spray #

What are the requirements for the propellants found in a manufactured organic vegetable cooking spray? (528.1) 6 December, 2021

Propellants present in organic cooking sprays would be a food additive and needs to be listed in Table 6.3 – Ingredients classified as food additives.

What are the requirements for a non-organic vegetable cooking spray (when organic oil is not commercially available (per Tables 6.3 and 6.5 Vegetable oil listings), including the propellant, used to coat baking trays as a release agent during organic preparation? (528.2) 6 December, 2021

Non-organic cooking sprays used to coat surfaces during preparation, leaving negligible amounts on the organic product, are classified as incidental additive 32-310 3.35. The agricultural components (and not the propellant) need to be listed in Tables 6.3, 6.4 or 6.5, per 32.310 8.1.2 c).

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