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
GE – genetically engineered
COS – Canadian Organic Standards
CAN/CGSB-32.311 – Permitted Substances Lists
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7.1 Apiculture #
Transition #
Does the three-year transition period apply to apiaries? (121)
No. The apiary site (colonies and hives) must comply with Clause 7.1.8.1 which specifies that 12 months of organic hive management is required prior to the harvest of organic honey.
New production sites in apicultural operations #
When a certified organic apicultural operator wants to add new production sites, does the application for those new sites need to be received 12 months prior to first harvest of honey on the new sites? (312.1)
Operators who are already certified need to notify their CB and list any new production sites (apiary site or forage locations) on their annual application for certification to be inspected along with the rest of the operation. Any new colonies established at these sites must be organic as per Clause 7.1.9.
Does the CB need to inspect new sites before they are added to an existing organic honey operation? (312.2)
The operator must notify their CB of the addition of these new sites and document that they comply with organic standards, including hive location requirements (Clause 7.1.10), and include this documentation in their annual application for certification. New sites must be inspected before honey produced from them can be sold as organic.
Certification of a new beekeeping operation #
If a new beekeeping operation submits an initial application for certification and purchases hives and colonies that are already certified organic, does the operation have to be under organic management for 12 months before its beekeeping products can be certified organic? (608)
No. The bees and bee products can immediately obtain organic status as soon as the operation has been verified as compliant by the certification body, provided that the new operation does not include any cultivated land for certification and that the apiaries are protected by a 3 km buffer zone free of prohibited substances (Clause 7.1.10).
Buffer zone #
Is a transition period required between the last use of a prohibited substance in the buffer zone and the time when the bees are feeding? (124, 278)
No. There is no set transition period required for the apiary buffer zone. No prohibited substances, other than fertilizers (see Clause 7.1.10), can be present when bees are foraging. As such, consideration must be given to chemically persistent materials previously applied (e.g., seed treatments) that could still present harm to the bees.
Does any use of a prohibited substance within 3 km of an apiary automatically disqualify the honey from achieving compliance with the standard? (115.1, 297)
No. All types of fertilizers are allowed. However, sewage sludge, GE crops and agricultural pesticides that are prohibited by the standard, including systemic seed treatments, are not allowed (Clauses 7.1.5 and 7.1.10). Other sources of potential contaminants should be assessed as to the level of risk they present. For example, if the risk of contamination is low, products prohibited by the Standard that are used by households within the buffer zone can be tolerated.
What potential sources of contaminants within the buffer zone need to be considered? (115.2)
Organic honey production typically cannot take place if the following are found within the buffer zone: high-density housing areas, such as subdivisions; golf courses; garbage dumps or landfill sites; industrial complexes; very busy roads; or commercial non-organic greenhouses/nurseries. There may be extenuating circumstances that must be assessed by certification agencies in each case.
Buffer zones of 3 km may be reduced if natural features restrict bee travel and abundant “compliant forage” is present (Clause 7.1.10 a). In this context, “compliant forage” means flowering plants that meet the requirements of the standard even if they are not certified organic.
Adding a nucleus hive #
When adding a nucleus hive to an existing organic apiary, shall it be considered as introduced bees (which are subject to commercial availability) or a replacement colony (which must be produced within operation or another established organic apiary)? (432)
An added nucleus hive (including both a queen and other bees) would be considered a replacement colony and therefore would be required to be produced within the operation or obtained from another established organic apiary (Clause 7.1.9).
Wax for foundation and comb foundation #
Can plastic foundation that has been dipped in non-organic beeswax be used when organic beeswax dipped plastic foundations are not commercially available? (506.1)
No. The wax covering the plastic foundation must be organic (Clause 7.1.13.3).
Can non-organic wax comb foundation be used when organic sources are not commercially available? (506.2)
No. Non-organic comb foundation may not be used. Organic comb foundation from the operation or from another source is required. (Clause 7.1.15.3)
Treated hives #
Reading Clause 7.1.15.7, does the term “treated hive” apply to the containers present at the time of the treatment only or does it also apply to any clean or untreated temporary containers, such as honey supers in summer time, and unused frames? (391)
The term “treated hive” applies to the container(s) present at the time of the treatment, and not to supers or frames removed from a hive prior to treatment Clause 7.1.15.7). However, the wax from any honey super frame or brood frame of the treated hive present or added during the 12-month transition period would need to be replaced with organic wax at the end of the transition period in order to return to organic production.
The bees in the colonies, that is the hives plus bees that were treated must also complete a transition period (Clause 7.1.8.1)
Non-organic sugar for feeding colony #
Clause 7.1.11.1 b) permits the use of non-organic sugar for colony feeding under certain conditions. Does this exception allow the use of sugar derived from genetically engineered beets? (363)
No. There are no exceptions to allow the use of GE sugar. The allowance in 7.1.11.1 b) is for non-organic, non-GE sugar to be used, as long as the conditions as outlined in that clause are met.
Organic beeswax #
Can beeswax be certified as organic? (442)
Yes. Beeswax generated by organic apiculture operations can be certified organic (Clause 7.1.1) with two exceptions: 1) when comb foundation was not sourced from organic hives (Clause 7.1.15.3); and, 2) when hives have been treated with synthetic allopathic drugs (Clause 7.1.15.7).
Heating temperature for the bottling of honey #
What is the maximum heating temperature for the bottling of honey? (625)
The temperature when bottling honey shall not exceed 47 °C (116.6 °F), the maximum temperature for decrystallization. If heated above this temperature, the honey can only be used as an ingredient in a multi-ingredient product as per Clause 7.1.16.4.
Honey harvested from wild bees #
Can honey harvested from wild bees be certified to Clause 7.1 Apiculture or 7.6 Wild Crop ? (382)
No. Wild bee products are not covered by the Canadian Organic Standards.
7.2 Maple products #
Buffer zone #
How close to a certified sugar bush can the use of a prohibited substance be allowed, without compromising the certification of the sugar bush? Are buffer zone needed? (13)
A sugar bush has the same buffer requirement as other crops. A minimum of 8 metres is generally required. However, this can be reduced if there are features that effectively buffer the sugar bush, such as permanent hedge rows, windbreaks, or roads (Clause 5.2.2). Also, depending on the circumstances, more than 8 metres may be necessary to prevent contamination.
Magnetization of maple water #
In maple production, is it permissible to use an anode that magnetizes maple water in order to keep the minerals in suspension and prevent calcareous deposits in the pan? (304)
No. It is prohibited to use technologies that may alter the intrinsic qualities of the product (Clause 7.2.7) and magnetization has that potential.
Well water through reverse osmosis #
Does well water meet the criteria for potable water if it has been run through a reverse osmosis filtering system? (430)
Yes. Water purified by reverse osmosis is considered potable.
Rinsing and cleaning of osmosis membrane #
Is it necessary to verify the quality of water used for cleaning/rinsing the osmosis membrane in maple equipment? (230)
Yes. If water is used during the production season, for cleaning/rinsing the osmosis membrane, potability needs to be confirmed (i.e.,, it must meet drinking water standards) as per Clause 7.2.13.2 a) 3).
Heating option for maple syrup evaporator pans #
Can natural gas be used to heat maple syrup evaporator pans? (346)
Yes, heating options, such as wood, heating oil, electricity, propane and natural gas, etc., that do not negatively affect the integrity of the syrup are permitted.
Waxed cardboard as fuel #
Can waxed cardboard pellets be used as fuel in maple syrup evaporators? (373)
Yes. As long as the operator can demonstrate that this type of fuel does not affect the integrity of the maple syrup.
7.3 Mushroom production #
Disease control #
In the production of organic mushrooms, can table salt be used as a spot control measure for disease on mushrooms? (132)
Yes. Refer to Salt in CAN/CGSB-32.311 Table 4.2, column 2.
Compliance of mushroom spawn including a substrate #
When mushroom spawn including a substrate (stick, log, brick) is listed on an organic certificate, is the permissibility of the substrate covered under certification? (603)
Yes. The mushroom spawn log could not be listed on an organic certificate unless the mushroom spawn (mycelium) is organic and the substrate materials are approved for use per Clause 7.3.2.
Substrate #
Do all the agricultural substances of the substrate (including all soil amendments and production aids) used at all phases of organic mushroom production need to be a) certified organic, or b) composted? Can conventional straw be used as compost feedstock for a composted substrate used to grow organic mushrooms? (4, 178, 602)
Standard 7.3.2.1 through 7.3.2.3 outlines the requirements.
| MATERIAL TYPE | ORGANIC | COMPOSTED |
| Wood | No, but must be free of prohibited materials. | No |
| Manure | 5.5.1 (32.310) outlines acceptable sources. Organic must be used if available. | Yes, and: 1) the Compost feedstocks requirements in CAN/CGSB-32.311 Table 4.2 apply; and, 2) either the Compost, Compost produced on the farm, or the Compost from off-farm sources criteria in CAN/CGSB-32.311 Table 4.2 apply. |
| Other agricultural substances (hay, straw or grains, etc.) | Yes if available. | 1) if organic is not available, then the materials must be composted. 2) the Compost feedstocks requirements in CAN/CGSB-32.311 Table 4.2 apply; and, 3) either the Compost, Compost produced on the farm, or the Compost from off-farm sources criteria in CAN/CGSB-32.311 Table 4.2 apply. |
Non-agricultural substances as mushroom substrate #
Can non-agricultural substances including peat moss be used as a mushroom substrate/growth medium or as a casing layer on top of a mushroom bed without being composted first? (385)
Peat moss is a substance in CAN/CGSB-32.311 Table 4.2 which has no specific use or restriction of usage. Therefore, it can be considered as an applicable entry for mushroom production under Clause 7.3.1. Other non-agricultural substances of CAN/CGSB-32.311 Table 4.2 can be considered as well unless their annotations restrict the substance to a specific usage which does not include mushroom production. Composting is only mandatory for substances of conventional agricultural origin in mushroom production (Clause 7.3.2.3).
Spawn marketed with growing substrate #
When marketing mushroom starter materials containing living spawn (e.g., mycelium loose in grain/or sawdust or embedded in a grow block/log/loaf/brick) as organic, are the components other than the mycelium exempt from the calculation of total percent organic ingredients in the final product? (471)
Mushroom starter materials in any format do not fall under Clause 9, therefore a calculation of the percentage of organic ingredients is not applicable. Spawn must comply with Clause 7.3.3 and the makeup of the starter material must comply with Clause 7.3.2.
Non-organic Potato Dextrose Agar to propagate mycelium #
Can non-organic Potato Dextrose Agar (PDA) be used to propagate mycelium (non-fruiting genetic material) to produce organic mushroom spawn? If so, can it include compounds and micronutrients that are not listed? (451)
Yes. Non-organic PDA is permitted if it can be demonstrated that PDA does not contain GE ingredients (see Agar, CAN/CGSB-32.311 Table 4.2) or compounds not listed in Table 4.2 (column 2) of CAN/CGSB-32.311 (see Clause 7.3.3).
Frass from insects in mushroom production #
In organic mushroom production, is insect frass considered an ‘other agricultural substance’ as per CAN/CGSB-32.310: 7.3.2.3, and would insect feed need to be organic? Or would the final product need to be composted? (548.2)
Insect frass is listed in the table 4.2 of CAN/CGSB-32.311. Unless the frass is organic, it shall composted since it is an agricultural substance per Clause 7.3.2.3.
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Hydrated lime in mushroom production #
Can hydrated lime be used as a spot treatment, disease control or disinfectant in organic mushroom production? (562)
Hydrated lime is permitted for disease control as indicated in Table 4.2 of CAN/CGSB-32.311.
7.4 Sprout, shoots and micro-greens production #
Parallel production #
Can organic and conventional sprouts be produced in parallel in the same facility if grown in visually distinguishable containers? (211)
Section 7.4 of the Standard does not contain or reference any restrictions related to parallel production; therefore, organic and conventional sprouts could be produced in the same facility. As per Clause 4.4.5, an identification system to distinguish organic and non-organic sprouts is required, which may include visually distinguishable containers and other methods.
Sprouts or shoots #
Please describe the difference between shoots and sprouts. (191)
Unlike sprouts, which are usually grown in water, shoots tend to be grown in a growth medium, such as a potting mix. Shoots tend to be cut, while sprouts are harvested and consumed with the roots attached. Production for both must comply with all criteria in 7.4 (Sprouts, shoots and micro-greens production).
Plants sold in pots #
Plants harvested within 30 days of planting fall under clause 7.4 and require the use of organic seeds. What if they are sold in pots to a customer who keeps them beyond the 30 days? Would they still need to be grown from organic seeds? (293)
Plants that are not harvested within 30 days of imbibition do not fall under 7.4 and the organic requirements in Clause 5.3 a) apply.
Soil volume in microgreen production #
Are the soil container volume criteria outlined in 7.5.5.2 and 7.5.5.3 applicable to containerized microgreen production (7.4)? (400)
No. Clauses 7.5.5.2 and 7.5.5.3 are not applicable to crops harvested within 30 days of imbibition such as microgreen production.
Substances for sanitizing seeds for sprouting and sanitizing sprouts, shoots, microgreens #
Which substances are compliant for sanitizing seeds for i) sprouting, ii) shoot and microgreen production, and iii) for sanitizing harvested sprouts, shoots or microgreens? (303)
As per Clause 7.14.10, substances for sanitizing seeds for i) sprouting and ii) shoots shall be limited to CAN/CGSB-32.311 Tables 4.2 and 7.3.
As per Clauses 7.4.12, 8.1 and 8.2, substances used for iii) sanitizing harvested sprouts, shoots and microgreens are limited to CAN/CGSB-32.311 Table 7.3.
Sprout rinsing #
What are the quality requirements for water used to rinse sprouts, shoots and microgreens? (84)
A water monitoring program should be in place to ensure water is potable as per the note in 7.4.4.
Is the rinsing of sprouts, shoots and microgreens with chlorinated water allowed? If so, in what concentration? (150)
Chlorinated water may be used to rinse sprouts, shoots and microgreens provided it does not exceed the level of chlorine in potable water (see Clause 7.4.12 referring to 8.2, and Chlorine compounds in CAN/CGSB-32.311 Table 7.3).
Inert substances and materials as growing media #
Can inert substances and materials be used in production of sprouts, microgreen and shoots produced in water? For shoots and microgreens produced in soil? What about growing on burlap cloth? On coconut coir/fibre? Can the ‘soil’ be sterilized? (299) (358)
For both water and growing media production systems, inert containers made of stainless steel and food-grade plastic are permitted (Clause 7.4.6). Growing media is restricted to soil-based systems (Clause 7.4.9) and must contain “both a mineral and organic fraction” (7.5.5.1 c)). Burlap, coconut coir or coconut fibre could be used as part of the ‘soil’ or could function as the ‘container’ or could function as ‘mulch’ in a soil-based shoot or microgreen production system (Clause 7.4.7). The operator must confirm that these materials are free from and/or have not been treated with prohibited substances and compliant with applicable CAN/CGSB-32.311 Table 4.2 listing annotations.
Organic bean sprout production #
Can bean sprout grown hydroponically be certified organic? (245)
Hydroponics is defined as the “cultivation of plants in aqueous nutrient solutions without the aid of soil” . As nutrient solutions cannot be used in organic sprout production (Clause 7.4.8), it is not considered hydroponics. Section 7.4 addresses the production of sprouts.
7.5 Crops Grown in Structures or Containers (formerly “Greenhouse crops”) #
Soil/soil-less mix #
Can a greenhouse operator take soil from outside and move it into the greenhouse? (267)
Yes, providing the soil has not been exposed to substances prohibited by the Standard for 36-months (See Soil, CAN/CGSB-32.311 Table 4.2 – column 1.
Does the use of a “peat moss/compost etc. mix” satisfy the requirements of 7.5.5.1 for “soil used in a container system”? (25)
It depends. 7.5.5.1 allows for container-grown production with soil. A compost and peat moss mixture may not contain the soil mineral fraction that is required, depending on the compost feedstocks. This fraction of the mix needs to contain at least 2% soil minerals by dry weight or volume. This same soil requirement applies to seedling and transplant production per Clause 5.3.7, except at first seeding before nutrition is necessary, per Clause 5.3.7 a)..
Growing media for seedlings #
Can annual seedlings be grown in a soilless media, even for the initial phase of propagation (1-2 weeks), and comply with organic standards? (204.1)
Yes. The use of a soilless media without nutrient supplementation is permitted at first seeding only . Once nutrition is necessary, the growing media needs to fulfill the requirements of soil as defined in Clause 7.5.5.1 (as referenced by Clause 5.3.7).
Growing media for propagules other than seedlings and transplants #
Clause 7.5.5.1 describes acceptable soil composition for container systems. However, layering and cutting propagation techniques may require an initial soilless rooting medium that provides no nutrition to propagated plants (water, moist air, perlite, vermiculite, sand, peat moss). Can soilless media be used for cutting and layering plant propagation? (204.2)
Plant nutrition must be based on soil as defined in Clauses 3 and 7.5.5.1. This nutrition cannot be brought through hydroponic or aeroponic production methods. However, as explained in Clause 5.3.7 a), when a propagule (other than tissue culture or micropropagation) needs no nutrition (cutting, layering, initial seed sprouting stage), it is possible to use a medium that does not meet criteria of Clause 7.5.5.1 as long as it does not contain prohibited substances (see Clause 1.5) and it is composed only of substances listed in Table 4.2 (Column 1) of CAN/CGSB-32.311.
Use of a prohibited fungicide in greenhouses #
If a grower covered the soil in a greenhouse container system and then sprayed a prohibited substance, can the soil be used in containers in subsequent cropping cycles if tests show that it does not contain any residues of the prohibited substance? (477.1)
No. Residue testing cannot be used as a substitute for required organic management practices; organic operators must not apply prohibited substances as per Clause 1.5.
Could this container soil be used for organic production after 12 months? (477.2)
No. Even though the soil was covered, and testing ,done 7 months later, showed no residue, a 36-months of transition is needed from the prohibited substance application for a compliant soil (see Soil, CAN/CGSB-32.311 Table 4.2). The 12-month period is only applicable to new operations per Clause 5.1.1. Alternating between organic and non-organic methods in this production unit is prohibited (Clause 5.1.7).
Composition of growing media #
May coconut coir be part of a growing medium used in container growing systems? (454.3)
Yes. Coir may be used according to the listing of Coir (coconut fiber) in CAN/CGSB-32.311 Table 4.2
Could a soil media blend of coir, peat moss, perlite and compost be used to grow perennials? (454.4)
No. The soil used in containers to grow perennials must also contain a soil mineral fraction, not including perlite and vermiculite, and contain of at east 2% sand, silt or clay per 7.5.5.1 c)..
Scope of Clause 7.5.5.1 #
Does section Clause 7.5.5.1 refer to all growing media products used in a container system, or solely professional products used in greenhouse growing? (498.1)
Yes. Clause 7.5.5.1 refers to any growing media used in a container whether it is blended on the operation or a purchased commercial product .
Applicable exception in Clause 7.5.5.1 #
Does the exception for seedling/starter mixes (Clause 7.5.5.1 d) only pertain to the 10% compost, or is there an exception for the 2% soil mineral fraction as well? (498.2)
Seedling/starter mixes may contain less compost, but must contain a 2% soil mineral fraction per Clause 7.5.5.1 c) and d).
Compost in seedling/starter mixes #
Do seedling/starter mixes need to contain any compost at all? (498.3)
No. Clause 7.5.5.1 d does not indicate a minimum compost content.
Disposal of greenhouse soil #
Under Clause 7.5.12, can operators dispose of greenhouse soils in cases where there is a risk of disease or pest propagation? (465)
Disposal of greenhouse soil to minimize the spread of a transmissible pest or disease is permitted only when a regulatory directive has been issued.
Soil and compost requirement in greenhouse production #
Is biochar in a soil mix considered part of the mineral fraction? (424.1)
No. Biochar is considered organic matter.
Are worm castings and vermicompost considered compost, and could they be used for the 10% requirement in 7.5.5.1 d? (424.2)
Yes, as they are both “products of carefully managed aerobic processes” (see definition of Compost in Cause 3). Please also refer to CAN/CGSB-32.311 Table 4.2 Worm castings.
Can the additional compost applications required in 7.5.5.4.a be in the form of compost tea? (424.3)
No. Compost tea is not considered compost.
Rock mineral compounds as mineral fraction #
Can rock mineral compounds, such as dolomite or gypsum, added to a soil/growing media be considered part of the mineral fraction as required in containerized production (7.5.5.1 e)? (563)
Yes. Sand, silt and clay as described in Clause 7.5.5.1 e) refer to particle size and would encompass rock mineral compounds (excluding perlite and vermiculite) permitted by this standard.
Forestry by-products as greenhouse compost #
Can bark or forestry by-products alone fulfill the 10% compost criteria for greenhouse container growing? (461.2)
No. Compost is a product of a carefully managed aerobic process (see definition of Compost, Clause 3).
Artificial lighting as a supplement to natural light #
Are systems reliant only on artificial lighting allowed under COS? (342.2)
Microgreens and shoot production may use systems reliant only on artificial lighting. For greenhouse crops, however, artificial lighting is permitted only as a supplement to natural light (see Clause 7.5.7). Growing plants in a predominantly opaque structure is prohibited.
Note: The organic greenhouse standards were not developed with growth chamber-like systems in mind.
How much sunlight is needed to fulfill the requirement of primary source of light as indicated by Clause 7.5.7? (551)
The sun shall be the primary source of light for photosynthesis on a year-round basis from sunrise to sunset. Supplemental light may be used to enhance the crop production, but sunlight use must be maximized every day of the year. I.e., growing plants in a predominantly opaque structure is prohibited, even if it has windows that permit some sunlight to reach the plants
UV-C light as an anti-microbial treatment #
Can the use of UV-C light as an anti-microbial treatment of crop surfaces be considered supplemental lighting per 7.5.7? (586)
Supplemental light permitted by Clause 7.5.7 is specifically for photosynthesis. UV-C disinfection devices’ light in direct contact with organic products during production as a microbial sanitation treatment is permitted. See the Non-ionizing radiation listing in Table 4.2 of CAN/CGSB-32.311.
Parallel production #
Is parallel production prohibited for greenhouse crops? (285)
Clause 5.1.4 prohibits parallel production in annual crops, including those grown in greenhouses with exceptions outlined in 5.1.4 a), b), c) and d). . However, if visually distinguishable organic and non-organic crops are grown, this is considered to be split production (Clause 5.1.3), which is permitted if: greenhouse systems (air, water, etc.) are sufficiently segregated so as to eliminate contamination risk of the organic crop by prohibited substances (1.5).
7.6 Wild Crops #
Wild seaweed #
Can wild seaweed meal be certified? (244)
Seaweed products can be certified under CAN/CGSB-32.312.
Buffer zone around wild crops #
Can wild harvest sites be located less than one kilometre from potential sources of environmental contamination such as golf courses, etc., if it is demonstrated that the wild crops are completely isolated from contact with prohibited substances by a clearly defined buffer, in accordance with Clause 7.6.4? (343.1)
No. There is no latitude in Clause 7.6.4 to reduce wild crop buffer zones, where required, to less than 1 km.
In the event that wild harvest cannot be certified (if 1 km requirement cannot be attained), is parallel production prohibited between crop production (plantation) and wild harvest? If so under what circumstances might it be allowed? (343.2)
If the wild harvest cannot be certified, parallel production from an existing organic plantation would be permitted; however, a new organic plantation could not be established. (Clauses 5.1.4 and 5.1.5)
Weed control for wild crops #
Can salt be used for weed control on the ground where organic wild harvested crops are stored? Even if that storage area is on a rock outcrop? (367)
No. Management practices shall avoid disturbance of the environment (Clause 7.6.2 b) and the wild area is to be “relatively undisturbed” (Clause 7.6.3); so, using salt as a ‘herbicide’ in the harvest or storage area is prohibited as it would disturb the ecosystem.
Honey harvested from wild bees #
Can honey harvested from wild bees be certified to the “Wild Crop” requirements in Clause 7.6? (382)
No. Wild animal products are not covered by the Canadian Organic Standards.
7.7 Organic insects #
Gelling agents for crickets #
Can gelling agents such as guar gum and xanthan gum be added into drinking water/feed for crickets? This will stop crickets from drowning especially as they are small when they first hatch. (511)
Yes. Gelling agents are permitted providing they are organic. Non-organic gelling agents are not permitted as none are listed in CAN/CGSB-32.311 Table 5.2.
