Requirements for certification of organic products at retail level under the Canada Organic Regime
Date: May 20, 2014
To: Conformity Verification Bodies designated by the Canadian Food Inspection Agency (CFIA) and Certification Bodies accredited by the CFIA
Subject: Requirements for certification of organic products at retail level under the Canada Organic Regime
The application of the Organic Product Regulations, 2009 (OPR) to organic products that are further prepared and/or packaged at retail and labelled as organic at the retail level is dependent on whether the product bears the Canada Organic Logo or whether the product is marketed inter-provincially or internationally.
Some examples or organic products that may be further prepared and/or packaged at retail:
- Par baked bread baked and packaged at retail store
- Coffee roasted and packaged at a retail store
- Bulk organic nuts packaged and labelled at a retail store
- Cookies baked from cookie mix at a retail store
1) Organic Product Bears the Canada Organic Logo
An organic product that is further prepared at retail, and bears the organic logo, must be certified in accordance with sections 12 and 13 of the OPR.
If an organic product is re-packaged or labelled at retail, and bears the organic logo, then the packing and labelling of the organic product is subject to the OPR. The retailer must have certification for the packaging and labelling in accordance with sections 14 and 15 of the OPR.
The certification body must certify the organic product and/or its packaging and labelling after verifying the organic contents and composition, the substances used, the production and processing methods and control mechanisms for purposes of compliance with CAN/CGSB 32.310, CAN/CGSB 32.311 and its general organic production principles (sections 13 and 15 OPR).
2) Organic Product is marketed inter-provincially or internationally and does not bear the Canada Organic Logo
The OPR apply to all organic products marketed inter-provincially or internationally, therefore must adhere to the same requirements as outlined above in scenario 1.
3) Organic Product is marketed intra-provincially and does not bear the Canada Organic Logo
An organic product (not bearing the organic logo) that is further prepared at retail and solely marketed intra-provincially is not subject to the OPR.
For instance, cookies baked at retail facility from a bulk organic cookie mix (from an out of province supplier) are not subject to the OPR. As long as cookies do not cross a provincial border, do not identify a certifier and do not carry the Canada Organic logo, the retailer can make an "organic" claim (if there are no prevailing provincial organic regulations otherwise). The retailer is not required to seek certification but must at all times be able to provide records to the CFIA which will show that the organic integrity of the cookies have been maintained, including as this may pertain to any other ingredients used in making the cookie (e.g. oil), the storage and handling of either the dry mix or the end-product, record keeping, etc.
Note that such products are subject to the Food and Drugs Act (FDA) and Consumer Packaging and Labelling Act (CPLA) which prohibit false and misleading claims on labels and advertising, as well as any provincial requirements including organic requirements.
Lead Auditor/ Vérificatrice principale
Canada Organic Office/ Bureau Bio-Canada
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