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
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Magnesium carbonate as anti-caking agent #
Can magnesium carbonate be used as an anti-caking agent in salt when used for food? (467.1)
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, 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.
Cheese Wax #
Can a coloured wax containing paraffin waxes (hydrocarbon or microcrystalline wax) and a colouring agent be used to coat organic cheese? (154)
Coloured 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. Edible paraffin wax coatings are not permitted. See Waxes, Table 6.5.
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 as per Clause 1.4 a) and the definition of ‘genetic engineering’ in Clause 3 of CAN/CGSB-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 listings in Tables 6.3 and 6.5. Additional requirements outlined in Clause 6.2.1 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 sub-part having a functional effect on the ingredient but not on the final product, nor is it declared on the product label; so, it is then permitted (Clause 9.1.2 of CAN/CGSB-32.310).
Use of desiccants #
Are silica gel pouches in containers of organic spices permitted? (439)
Yes. Silica desiccants, which includes silica gel pouches, may be used as silica, that is silicon dioxide, is listed in Table 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 (Clause 8.1.6 of CAN/CGSB-32.310) and other food-contact surfaces (Clause 8.1.1 of CAN/CGSB-32.310)
Fumed silica #
Is the use of fumed silica, a processed form of silicon dioxide, restricted by CAN/CGSB-32.310 1.4 b) as a product of nanotechnology? (660)
No. Fumed silica is not considered a product of nanotechnology and is permitted as a food additive or a processing aid per Tables 6.3 and 6.5 Silicon dioxide.
Carriers #
Can permitted substances contain carriers? (376)
Yes, but there are restrictions. See Carriers, Table 6.3.
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 CAN/CGSB-32.311.
Indirect Processing Aids #
Can products not listed on in CAN/CGSB-32.311 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 CAN/CGSB-32.311 can only be used as processing aids if they are organic. Non-agricultural products must be on CAN/CGSB-32.311. See definition of “incidental additives” in Clause 3 and Clause 8.1.2 in CAN/CGSB-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.
Meat curing agent – Cherry extract #
Is cherry extract powder permitted as a meat curing agent? (534)
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 an agricultural ingredient which can be used in the manufacture of organic products. Organic stevia must be used is commercially available.
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)
Yes. Unless the specific starch is listed in CAN/CGSB-32.311, 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 apply? (564)
No. If the vitamins and minerals are legally required (Table 6.4), 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) and b) of 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)
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 Table 6.4 Vitamins and mineral nutrients. The ingredient and nutrients shall comply with prohibitions in Clauses 1.4 and 1.5, 9.2.1 d) and 9.2.2 a) of CAN/CGSB-32.310) as per Clause 6.2.1 of CAN/CGSB-32.311.
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 Tables 6.3 or 6.4? (589.1)
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)
a) dried fruit with added sulphites?
No, sulphites are prohibited per Clause 1.5 f) of CAN/CGSB-32.310, with one exception for alcohol production (see Sulphur dioxide, anhydrous (SO2) in Table 6.3).
b) tea extract extracted with a solvent not listed in 32.311?
Yes,
- providing the tea extract has been minimally processed and is still considered agricultural per the definition of “agricultural ingredient” in CAN/CGSB-32.310 Clause 3,
- if all sub-parts, except processing aids such as extractant solvents (SIC Q&A 20.1), are listed in Table 6.3 or 6.5 per 1.5 f) of CAN/CGSB-32.310, and
- conditions of CAN/CGSB-32.310 9.2.1 d) (95% organic content) or 9.2.2 a) (70-95% organic content) have been met.
c) alcoholic beverages (rhum, tequila, etc.)?
Yes,
- providing the alcoholic beverage has been minimally processed and is still considered agricultural per the definition of “agricultural ingredient” in CAN/CGSB-32.310 Clause 3,
- if all sub-parts, except processing aids (SIC Q&A 20.1), are listed in Table 6.3 or 6.5 per 1.5 f) of CAN/CGSB-32.310, and
- conditions of CAN/CGSB-32.310 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 by Health Canada. To be permitted they would need to be listed in Table 6.3 of CAN/CGSB-32.311, or qualify as “agricultural ingredients” per the definition in CAN/CGSB 32.310 Clause 3, which they do not.
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 Table 6.3 or 6.4.
f) cured meat (ex. Bayonne ham)?
Yes,
- providing the cured meat has been minimally processed and is still considered agricultural per the definition of “agricultural ingredient” in CAN/CGSB-32.310 Clause 3,
- if cured and prepared without prohibited substances per CAN/CGSB-32.310 1.5 f),
- all sub-parts, except processing aids (SIC Q&A 20.1), are listed in Table 6.3 or 6.5 and
- conditions of CAN/CGSB-32.310 9.2.1 d) (95% organic content) or 9.2.2 a) (70-95% organic content) have been met.
g) wild harvested herbs?
Yes,
- providing the herbs have been minimally processed and are still considered agricultural per the definition of “agricultural ingredient” in CAN/CGSB-32.310 Clause 3,
- if prepared without prohibited substances listed in CAN/CGSB-32.310 1.5 f) and
- all sub-parts, except processing aids (SIC Q&A 20.1), are listed in Table 6.3 or 6.5, and
- conditions of CAN/CGSB-32.310 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 as per CAN/CGSB-32.310 8.1.3; hydrogenated oils are not listed in Table 6.4 of CAN/CGSB-32.311.
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 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 in CAN/CGSB-32.311? (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. GE rules regarding the inclusion of substrates as outlined in Clause 6.2.1 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)
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, Table 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)
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 Table 6.4. Per CAN/CGSB-32.310 9.2.1 a), ingredients classified as food additives are subject to substance listing annotations and restrictions specified in Clause 6.2 of CAN/CGSB-32.311. As there are no organic commercial availability requirements listed in the annotation for Vitamins and minerals in Table 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, Table 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)
No. Vitamins and minerals are permitted only if legally required or voluntarily added to non-dairy substitute products as listed in Table 6.4.
Omega-3 Fatty Acid in infant formula and baby food #
Can Omega-3 Fatty Acid for use in an organic baby food or infant formula be reviewed for compliance as a legally required nutrient under the listing of Vitamins and mineral nutrients in Table 6.4? (624.1)
No. It is not a vitamin or mineral. Omega-3 and Omega-6 fatty acids are permitted for infant formulas (and not baby food) to achieve levels as legally required. See Fatty acids, Table 6.4.
When reviewing Omega-3 Fatty Acid, such as the docosahexaenoic acid (DHA), as an ingredient, do all sub-parts including preservatives need to comply with Section 6? (624.2)
Yes. As of COS 2026, DHA or ARA Omega-3 Fatty Acids are permitted for infant formulas to achieve levels of fatty acids legally permitted, as indicated in the Long-chain polyunsaturated fatty acids (LCPUFAs) listing in Table 6.4,
- providing they comply with all conditions of Clause 6, all annotations therein, and,
- if not organic, must be prepared without prohibited substances listed in Clause 1.5 f) of CAN/CGSB-32.310 and
- all sub-parts, except processing aids (SIC Q&A 20.1), are listed in Table 6.3 or 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 (CAN/CGSB-32.310 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 (CAN/CGSB-32.310 9.1.2).
Use of calcium chloride in beer making #
May calcium chloride be used as an ingredient in beer making? (482)
Yes. Table 6.3 of CAN/CGSB-32.311 allows the use of calcium chloride for beer making.
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)
Yes. CAN/CGSB-32.311 Table 6.3 has a listing for Dibasic ammonium phosphate (DAP) permitting its use as a yeast and bacterial food for vinegar and alcohol production. It cannot be added to the final product.
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)
Non-organic yeast may be used provided that all other prohibitions of CAN/CGSB-32.310 are met, including Clause 9.1.2. Clause 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)
Propellants present in organic cooking sprays would be a food additive and need 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)
Non-organic cooking sprays used to coat surfaces during preparation, leaving negligible amounts on the organic product, are classified as an “incidental additive” as defined in CAN/CGSB-32-310 3. The agricultural components (and not the propellant) need to be listed in Tables 6.3, 6.4 or 6.5, per CAN/CGSB-32.310 8.1.2 c)).
Potassium bisulphite in wine production #
Is Potassium bisulphite permitted for use in wine production? (591)
Yes. Potassium sulphite is listed in Table 6.3 allowing both bi-, and meta- forms
Use of collagen casings #
Are collagen casings listed in Table 6.4 permitted for use in the preparation of pork, beef or veal sausages? (639)
No. Collagen casings are permitted only for poultry sausage as indicated in the listing annotation.
