Date: December 10 ,2020
This notice provides clarification on the implementation of revised Canadian Organic Agriculture Standards published on December 11, 2020.
This update included:
• CAN/CGSB 32.310 – Organic Production Systems – General Principles and
Management Standards; and
• CAN/CGSB 32.311 – Organic Production Systems – Permitted Substances Lists.
As per ISO 17065, when a certification scheme introduces new or revised requirements that affect the client, the certification body (CB) shall ensure these changes are communicated to all clients. The CB shall verify the implementation of the changes by its clients and shall take actions required by the scheme. As per section C.5.1 of the Canada Organic Regime (COR) Operating Manual, the CB is required to notify all of its operators of any amendments to the regulations or standards within 2 months after publication.
Under Part 13 of the Safe Food For Canadians Regulations (SFCR) all new and returning applicants for certification must meet the most recent versions of the standards. As per section C.5.2 of the COR Operating Manual, a period of up to 12 months can be allowed to previously certified operators to come into compliance with any changes to the Canadian Organic Standards.
Some of the revisions in the standards may require more than 12 months to implement. When applicable, any period longer than 12 months is specified within the standards.
• Starting April 1, 2021 the conformity verification bodies (CVBs) designated by the CFIA are to assess CFIA-accredited CBs during on-site, witness and verification audits to confirm they are trained and ready to certify organic products to the updated standards.
• CBs must update training materials, certification procedures and checklists to reflect the 2020 versions of the standards.
• By March 31, 2021, all verification officers and certification staff must receive training on the revised standards that specifies the differences between the 2015 and 2020 versions.
• Records of all related CB training sessions, materials and attendees must be maintained and provided to the CVB upon request.
• During the implementation period if a CB finds that an operator is not producing organic products according to one of the new requirements, then a non-conformity can be issued and addressed prior to the end of the implementation period.
• All certification documentation must reflect the revised standards by December 11, 2021.
Operators of organic products responsibilities:
• Operators certified prior to December 11, 2020 are encouraged to produce organic products according to the revised standards throughout the 12-month implementation period. Except where additional time has been specifically granted within the standards, operators must be fully compliant with the new requirements by November 26, 2021.
• Organic products produced and certified before December 11, 2020 in compliance with the previous versions of the standards (CAN/CGSB 32.310-
2015 and CAN/CGSB 32.311-2015) remain compliant with Part 13 of the SFCR. These products can continue to be marketed as organic after December 11, 2021.
• Ingredients certified as organic before December 11, 2021 that are in compliance with the previous version of the standard can continue to be used in manufacturing products certified to the new versions of the standards and will be accepted as compliant with Part 13 of the SFCR.