CFIA have published information on the Interpretation of clause of Clause 347 (1) of SFCR: Packaging and labelling certificate should only be issued to contract service providers that package and label organic products on behalf of the organic product certificate holder.
1. Relevant Reference(s):
• SFCR P. 13 s. 342: Packaging and labelling activities can be performed by “a person who holds a certificate that is granted under section 345 or 348”.
• SFCR P.13 s. 344: This section describes the required contents of an application for organic certification, “in the case where a person packages and labels the food commodity on behalf of the applicant….a copy of the certificate referred to in subsection 348(2).” This implies that the product certificate holder may only subcontract the packaging and labelling of its products to an operation certified to do so.