On September 17, the Organic Council of Ontario hosted a webinar on proposed changes to the Canadian Organic Standards. Public comments will be accepted by the Canadian General Standards Board until September 30, 2019.
Panelists included: Hugh Martin, Rob Wallbridge, Joel Aitken, Norm Hansen, Rochelle Eisen, Simon Jacques, Nicole Boudreau
#YourStandardsYourSay: Changes to the 2020 Canadian Organic Standards
2020 Standards Changes
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Panelists & Agenda
12:00 Carolyn Young: Introduction and Welcome
12:05 Hugh Martin: Overview of the Standards Review Process
12:10 Rob Wallbridge: Updates on Crops and Parallel Production
12:20 Joel Aitken: Updates on Livestock Issues - ruminant, pork, poultry
12:30 Norm Hansen: Update on Greenhouse and Container Issues
12:40 Rochelle Eisen: Sprouts, Shoots and Microgreens
12:50 Simon Jacques: Update on the Permitted Substances List (Crops)
1:00 Rochelle Eisen: Updates on Preparations
1:10pm Nicole Boudreau: Next Steps in the Review Process
1:20pm Question and Answer
What Are the
• Are referred to by the regulations
• Adhere to International Standards Organization
• Outline the principles that guide organic
agriculture, and specify the methods required to
grow certified organic food
• Contents are generated by organic sector, voted on
by the technical committee, owned by CGSB
• While US standards are embedded into
government regulations, Canadian Standards are
distinct from the regulations.
Canadian Organic Standards - 2020 revision
• SCC/CGSB require us to revise COS every 5 years
• During past year
• 80+ conference calls 2-3 hours each
• TC 4 conf call mtgs + 2.5 day in-person
• 220+ comments reviewed (44 requests were rejected) by Working
• Draft revised standard released for public comment July 2, 2019
• 90 day public comment period ends Sept 30, 2019
• Comments reviewed by working groups – any necessary revisions to draft
• Approval by SCC as a National Standard of Canada
• Publish end of 2020 (Nov?)
• 2021 operators come into compliance
Parallel Production – A compromise revision
5.1.4 The enterprise operation can be converted one unit at
a time, and each converted unit shall respect the
requirements of this standard. The exception to this norm,
parallel production, is only allowed in the following cases:
annual crops harvested during the final 24 months of the
transition period when fields are added to existing
operations, perennial crops (already planted), agricultural
research facilities and production of seed, vegetative
propagating materials and transplants.
Parallel Production – Clarifying definition
parallel production (production
simultaneous production or preparation
of organic and non-organic crops,
including transitional crops, livestock
and other organic products of the same
or similar, visually indistinguishable
varieties that are visually
indistinguishable by the common person
when the crops, livestock or products
are positioned side by side.
Parallel Production – What hasn’t changed
5.1.3 The enterprise operation shall aim at a complete transition of its production.
During the transition period, the enterprise operation can maintain, in addition to
the production in transition, a non-organic system of production (split operation)
that shall be entirely separate and identified separately, pending its incorporation
into the overall transition process.
5.1.5 The following special conditions shall be observed for parallel production:
a) The operator shall clearly demonstrate that the identity of the crops so
produced can be maintained during their production, harvesting, storage,
processing, packaging and marketing;
b) The operator shall maintain verifiable, accurate records of both non-organic and
organic produce and product storage, transportation, processing and marketing.
NOTE Parallel production crops, both organic and non-organic, are inspected just
prior to harvest and an audit of all parallel production crops occurs after harvest.
5.1.6 All production units shall have distinct, defined boundaries.
5.1.7 Production methods shall not alternate between organic and non-organic on
a production unit.
Seed – Organic sources
5.3 Seeds and planting stock
5.3.1 Organic seed, bulbs, tubers, cuttings, annual seedlings,
transplants, planting stock, and other propagules shall be
used. The following exceptions or conditions apply:
5.3.2 Organic seed and planting stock may be:
a) treated, primed, pelleted, or coated with substances listed
in Tables 4.2 & 4.3 of CAN/CGSB 32.311 and Table 7.3 of
Seed – Non-organic sources
5.3.3 Non-organic, untreated seed and planting stock or seed treated with substances listed in
Table 4.3 of CAN/CGSB-32.311 are permitted provided that:
a) the organic seed or planting stock variety is:
not produced on or available from within the operation; ; and or
b) the organic seed or planting stock is not commercially available, and a documentedreasonable
search involving potential, known organic suppliers has been conducted.
c) when treated, primed, pelleted or coated, it is with substances listed in Table 4.2 or 4.3 of
i) seed primed with substances not listed on Tables 4.2 and 4.3 of CAN/CGSB-32.311 and Table 7.3
of CAN/CGSB-32.311 isare permitted providing that the priming process does not contain
pesticides not listed on Tables 4.2 and 4.3 of CAN/CGSB-32.311 and Table 7.3 of CAN/CGSB-32.311
ii) non-organic perennial planting stock treated with substances prohibited by 1.4 d), 1.4 e), 1.4 f)
or 1.4 g) shall be managed in accordance with this standard for at least 12 months before the first
harvest of organic product. The land on which non-organic stock is planted is subject to the
requirements of 5.1.1.
iii) when seeds are treated with substances necessary for compliance to international, federal or
provincial phytosanitary or food safety regulations and approved for use by regulatory agencies
such as PMRA.
Seed – New definitions
seed coating (enrobage des semences):
a substance applied to the surface of a seed for a function distinct
from seed pelleting.
seed pelleting (pralinage des semences):
augmenting a seed with substances to increase the size of seed to
seed priming (trempage des semences):
adding water-based solutions into seeds, before sowing, to
improve the uniformity and speed of germination. Once wetted,
the seed is dried to allow for shipping and short-term storage.
Priming substances are not designed to enter the seed.
seed treatment (traitement des semences):
adding pest control products, plant growth regulators, inoculants
or fertilizers, etc., to seeds to assist with their field performance.
Can be performed pre- or post-sowing.
All Livestock – Outdoor Access
• All stocking density tables have been updated.
• They have been generally clarified as to which specific animals the
densities apply to and exactly what type of area they require.
• Minor surpasses of allowances in poultry and swine are now
Completely reworded and renumbered with
no major concept changes (more specifics
1. Organized under heading: “hydroponic
and aeroponic productions are
2. Diversity specified: 10% compost and 2%
3. Volume further specified for crops other
than staked crops
4. Staked crops updated
5. Note updated.
Reworded supplemental lighting and added
1. Section 7.5.4:
• Sunlight preferred
• Sunlight required for crops > 60 days
• Artificial allowed for crops < 60 days
2. Section 7.5.9 adds restrictions for
• Only biological CO2
• Reuse transpiration water
• Drain water must be reused or treated.
1. Title changed to: “Protected Crops and
2. If crop <30 days must be organic seed.
3. All CO2 allowed
4. Cultural & Sanitation practices
SSM (sprouts, shoots and
• Reorganized so it is more logical
• States artificial lighting is allowed
• Outlines type of growing containers
• Inert (steel, plastic, glass) for both water & soil systems
• untreated plant based materials (burlap, coir) permitted for soil systems only
• Stipulates soil must have a mineral and organic fraction
Crops covered by 7.4
& water testing
• SSM crops harvest within 30 days (no change)
• Added nanoshoots, living greens
• Clarified it does not include whole head products
• Water testing change to informative note
“a water monitoring program should be in place to ensure
water is potable”.
• Eliminates food safety criteria from standard
Proposed Changes to 32.311
Permitted Substances List for Crop Production
The most noticeable changes are administrative/organizational.
1. Combining table 4.2 (Soil amendments & Crop Nutrition) with table
4.3 (Crop Production Aids) into 1 table with 2 columns. This was
done to reduce duplication, as many substances were listed in both
2. Reducing use of the word “non-synthetic”, as this was proving
difficult to interpret. In general, wording was changed to
“substances listed in table 4.2”
• Clarification that “Microbial products” can be used as fertilizers. It
was proposed that microbial products should not be allowed unless
all substances used in their production appeared in table 4.2. The
working group rejected this proposal on the basis that it was
inconsistent with the listings for fertilizers of plant or animal origin,
which can be produced with substances not on the PSL.
• Addition of “Struvite” (magnesium-ammonium phosphate) made
from waste streams, except human sewage. Struvite is a synthetic
phosphate mineral that can be precipitated from liquid waste as a
way of recovering phosphorus, preventing waterway pollution and
displacing non-renewable mined phosphorus. It was proposed to
allow struvite made from all wastewater streams, but the TC was
divided on allowing it from sewage plants.
• 2 synthetic preservatives now allowed in seaweed extracts. Currently,
chemical extracts are allowed. Extracts which do not use these
chemicals can use preservatives instead.
• The addition of a positive list of allowed micronutrients (previously
the term was not defined, but some micronutrients had their own
listing. Micronutrients are now defined as: ): Iron, Manganese, Zinc,
Copper, Molybdenum, Boron, Chlorine, Silicon.
• Are you using a micronutrient not on this list? Nickel? Sodium?
• Related: new listing “Silicon, silica & silicates”. Synthetic silicates now
allowed as a fertilizer (previously sodium silicate only was allowed for
“tree fruit and fibre processing”). It may be unclear if ALL synthetic
forms of silica are allowed (ex: monosilicic acid)
Synthetic / Non-synthetic jargon
• Historical - syn/non-syn replaced ‘natural’ which we
all could relate to. Syn/non-syn is difficult to assess.
• This revision
• will eliminate hours and stress trying to figure out if a
material is synthetic or non-synthetic helping to level the
playing field for all producers
• e.g. soap annotation “shall consist of fatty acids derived
from animal or vegetable oils.” Even though that sounds
non-synthetic technically almost all soaps are synthetic
because the key ingredients, fat and lye are chemically
altered by heat.
Instead of syn/non-syn
• Annotations identify what sources are permitted or in some cases
what sources are prohibited.
• Potassium chloride (6.3): From mined sources such as sylvite,
carnalite, and potash.Non-synthetic sources.
• Essential oils (7.3): Derived from plant sources and substances in Table 6.3
Extraction solvents and precipitation aids. May contain permitted carriers (see
Table 6.3 & 6.4 Carriers).
• Overall impact? No notable change in permitted organic farming
practices or in the scope of permitted substances. Instead, these
changes will make it easier to know what substances are allowed.
• Ensuring each non-agricultural component of a non organic
ingredient is listed on the PSL has proven to be impossible.
• This revision removes most of the burden
9.1.2 The Eevaluation of product composition shall exclude non-
agricultural sub-parts of ingredients listed in Tables 6.3 & 6.4 that
have a technical or functional effect on the ingredient but not on
the final organic product, and are not declared on the final
organic product label. These ingredient sub-parts may be present
in the final organic product but only in insignificant amounts. This
includes ingredients such as anticaking agents, carriers and fillers,
preservatives, stabilizers, pH adjusters or buffers. Theand
calculation of organic percentages shall account for all constituent
ingredients or ingredient sub-parts, distinguishing between
organic and non-organic components of each ingredient
contained in the product.
• Many thought when the water was part of
purchased ingredients – like so
• 95% organic green tea (includes water)
• 5% non-organic flavour
Product qualified for organic status
• But take out that ingredient water and
• 94% water
• 1% organic green tea extract
• 5% non-organic flavour
Product does not qualify for organic status
• The math was being done both ways across
the country depending on the certifier
leading to confusion and inconsistency
between operators and CBs.
• With the 2020 publication water content of
an ingredient (where water is identified as
an ingredient of the ingredient) will need to
be subtracted out.