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Canadian Organic Standards

Final Questions & Answers

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Permitted substances lists for preparation

Updated on August 16, 2021
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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)
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 Enzymes, PSL, Tables 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.

Version 2020

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)
Yes, carriers present in permitted substances are subject to the requirements of “Extraction solvents, carriers and precipitation aids” unless they are organic ingredients.

Version 2020

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, 3.30 (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.

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.

Version 2020

There are no restrictions for the use of Sodium citrate in the 2020 version. So, QAs 405a and 405b will be deleted.

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.

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 sulphate 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.

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.

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