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Canada Organic Regime operating manual
Part B Accreditation of certification bodies (CB)

Participation in the Canada Organic Regime (COR) accreditation program is not intended to prevent certification bodies (CB) from carrying out other business activities, especially those involving the certification of products not covered by the scope of the regulations.

Operations resulting from these other activities should neither constitute an infringement nor result in conflicts of interest with the certification program accredited by the CFIA.

B.1 Objective

This section outlines the CB accreditation requirements and the requirements for the CVB assessing and monitoring the CB responsible for the certification under the COR.

The CVB shall ensure that CB seeking CFIA accreditation to offer certification under COR are compliant with the requirements of part 13 of the SFCR including ISO/IEC 17065 and the requirements of this manual.

Accreditation is obtained as a result of a rigorous process. The applicant shall undergo an assessment conducted by CVB in accordance with ISO/IEC 17011 to verify the CB's compliance with ISO/IEC 17065, the requirements of the COR Operating Manual, the CFIA directives and memos.

On the recommendation of the CVB, the CFIA accredits the applicant CB. The CFIA shall provide the accredited CB with an accreditation number. The accreditation number granted by the CFIA to a CB means the latter, being a competent, responsible and qualified party has the financial and organizational capacity to manage a certification program that shall result in consistent and credible certification decisions.

B.2 Initial CB accreditation

B.2.1 Application By CB and document review by CVB

  • B.2.1.1 An applicant applying for accreditation under the COR shall submit an application form to a designated CVB.
  • B.2.1.2 In addition to the application form, the applicant shall provide all supporting documents as listed in section B.11 and any additional documents deemed essential for the assessment as requested by the CVB.
  • B.2.1.3 The CVB shall send acknowledgement of receipt to the applicant CB within 10 working days, shall notify the CFIA about the application, and proceeds with the assessment.
  • B.2.1.4 The applicant shall pay the application fees determined by the CVB.
  • B.2.1.5 The CVB shall conduct a resource review (as of ISO/IEC 17011 section 7.3) to assess the CVB's ability to carry out the assessment.
  • B.2.1.6 The CVB shall prepare for the assessment (as per section 7.5 of ISO/IEC 17011).
  • B.2.1.7 The CVB shall conduct the document review against the COR requirements (including ISO/IEC 17065, part 13 of the SFCR, COR Manual, CFIA Directives and Memos) and shall communicate the findings from the document review to the CB. It shall include the identification of any nonconformities (NCs) and/or information requests.
  • B.2.1.8 The CVB shall require the applicant CB to provide response for all NCs and information requests. The CVB shall determine which NCs shall be resolved before proceeding with an on-site assessment.
  • B.2.1.9 The CVB may communicate with the applicant CB or an independent source, in order to obtain any other information needed to examine the application.

B.2.2 On-site assessment of CB

  • B.2.2.1 The CVB shall conduct the assessment following the requirements outlined in section 7.6 of ISO/IEC 17011.
  • B.2.2.2 The CVB shall analyze all relevant information and evidence to determine the competence and extent of conformity of the applicant with the COR requirements, including compliance with part 13 of the SFCR, ISO 17065, COR Operating Manual, the CFIA directives and memos.
  • B.2.2.3 The CVB shall select an assessment team that shall proceed with an on-site assessment covering the applicant's certification activities. The CVB may assign 1 or more members of its personnel and may also retain the services of external auditors or technical experts or both.
  • B.2.2.4 The appointed CVB auditor(s) should not have been employed by a CB in a position within a 2 year period from the appointment.
  • B.2.2.5 The criteria relative to a CVB auditor's competence, qualifications and experience shall include, among others:
    • B.2.2.5.1 Knowledge and understanding of the COR's requirements including accreditation criteria and procedures
    • B.2.2.5.2 Knowledge of the Canadian Organic Standards and generally accepted experience such as practical experience in production, processing, inspection or certification management would be a major asset relative to conformity assessments
    • B.2.2.5.3 Knowledge of auditing principles, procedures and methods including interviewing techniques and an ability to draft reports in compliance with ISO/IEC 19011 requirements
  • B.2.2.6 The names of the assigned auditors shall be communicated to the CB, who may, based on serious concerns, object to the assignment of any auditor mentioned. In light of the reasons stated by the CB, the CVB may appoint another auditor or retain the one initially selected.
  • B.2.2.7 In circumstances where the applicant CB has multiple offices, the CVB shall visit the main office and will select to visit the CB satellite offices based on the key activities (ISO 17011 7.4.5) concerning the certification process.
  • B.2.2.8 The CVB shall send to the applicant CB the information, documentation and relevant instructions needed to conduct witness audit and verification audits, as well as an estimate of expenses pertaining to this visit.
  • B.2.2.9 The CVB auditor(s) shall begin every visit with an opening meeting with the applicant's representatives and at a minimum explain the audit objectives relative to accreditation criteria, review the audit plan, and confirm the scope of the evaluation.
  • B.2.2.10 The CVB auditor(s) shall conduct interviews with the relevant CB personnel including managers, employees and contractors, as required.
  • B.2.2.11 The CVB auditor(s) shall carry out rigorous examination of a sampling of the applicant CB certification files. The CVB auditor(s) shall randomly select the files to be included in the sample, with consideration given to the CB's certification and geographical scope. The examination of files shall ensure that:
    • B.2.2.11.1 The documentation found in an operator's file (for example, signed contracts, initial and updated production/preparation plans, letter of good standing in case of CB change, inspection reports, certification, certification decision and other correspondence, approved inputs, labels, copies of certificates) are complete and up to date
    • B.2.2.11.2 The inspection reports include sufficient information and evidence needed to make a proper certification decision
    • B.2.2.11.3 The certification decision made by the applicant CB is in line with the evaluation of the operator's production/preparation plan and the results from the inspection report
    • B.2.2.11.4 The applicant CB has verified the implementation of all corrective measures that were requested from the operator
    • B.2.2.11.5 The applicant CB is operating in accordance with the relevant sections of the ISO/IEC 17065
  • B.2.2.12 The CVB auditor(s) shall base the quantity and selection of files to be examined on the following sampling rules:
    • B.2.2.12.1 The CVB auditor(s) shall carry out file reviews according to the table below.
Table 3: Number of files to be reviewed for CB initial accreditation
Number of active operators registered with the CB under COR Number of files to be reviewed
Less than 5 All files are subject to a full review
Less than 100 Minimum of 5 full reviews Table note 2 (the number could be increased at the discretion of the CVB)
101 to 240 Minimum of 10 Table note 3 files, 5 of which must be full reviews
241 to 400 Minimum of 12 files, 6 of which must be full reviews
401 to 1000 Minimum of 15 files, 7 of which must be full reviews
More than 1000 Minimum of 20 files, 10 of which must be full reviews
  • B.2.2.13 The CVB auditor(s) shall verify the competence of the personnel involved in the certification activities of the CB, within the framework of the positions they occupy. The CVB auditor shall review these employees' competence, training and education and shall conduct interviews with some of them.
  • B.2.2.14 The CVB auditor shall conduct at least 1 witness audit as a means of verifying that the applicant CB is implementing its procedures satisfactorily.
  • B.2.2.15 The CVB auditor shall, during the witness audit(s), observe the VO preparation for the inspection and his/her adherence to the CB's inspection procedures.
  • B.2.2.16 For CBs that do not yet have clients in the organic sector, the CVB shall conduct a witness audit as soon as the CB has an operator.
  • B.2.2.17 The CVB auditor shall present the findings from the on-site visit and the witness audit to the CB in a format determined by the CVB.
  • B.2.2.18 The CVB shall establish its own reporting procedures in compliance with ISO/IEC 17011.
  • B.2.2.19 The CVB shall allow the applicant CB a time period of 30 working days from receiving the CVB report to submit the specific actions taken or planned to be taken in order to resolve the identified NCs.
  • B.2.2.20 The CVB shall evaluate whether the responses and action taken by the applicant CB to resolve any NC appears sufficient and effective as outlined in sections 7.6.8 and 7.6.9 of the ISO/IEC 17011.
  • B.2.2.21 If the CVB determines that the provided information is not sufficient or adequate, further information may be requested and/or additional assessment activities may be conducted.
  • B.2.2.22 CFIA may accompany the CVB assessment team to observe the accreditation process.

B.2.3 CVB recommends accreditation to the CFIA

  • B.2.3.1 The CVB shall decide to either recommend or not recommend the accreditation of the applicant CB to the CFIA.
  • B.2.3.2 The CVB shall only recommend the applicant CB for accreditation if all identified NCs have been adequately addressed by the applicant and when the CVB is confident that the applicant CB has fulfilled the requirements for accreditation.
  • B.2.3.3 The CVB shall send to the CFIA the recommendation decision in writing and shall provide to the CFIA a copy of the CVB evaluation report on the applicant CB and any other relevant information to support the accreditation recommendation.
  • B.2.3.4 The CFIA shall review the CVB recommendation. If the CFIA decides to confirm the CVB recommendation, it shall grant accreditation to the applicant.
  • B.2.3.5 If the CVB recommends to not accredit the applicant CB, the CVB shall send a notice to the applicant CB by registered mail or email (with confirmation of receipt from the applicant), stating the reason for the decision. The applicant CB has the right to request that the CFIA review the CVB decision within 30 working days after receipt of the notice.
  • B.2.3.6 If the CFIA does not agree with the CVB recommendation the CFIA shall grant accreditation to the CB.
  • B.2.3.7 The CFIA shall inform the applicant CB and the CVB on its decision to accredit or not to accredit.

B.2.4 CFIA grants the accreditation

  • B.2.4.1 The CFIA shall inform the applicant CB and the CVB of the accreditation decision made by the CFIA by issuing an accreditation letter.
  • B.2.4.2 The CFIA shall grant accreditation valid for 5 years beginning on the date the accreditation number is granted by the CFIA.
  • B.2.4.3 The CB shall be re-assessed, recommended by a CVB and accredited by the CFIA for another 5 years before the end of the accreditation cycle in order to have its accreditation renewed once this period has ended.

B.2.5 Requirements for granting accreditation number to the CB

  • B.2.5.1 CFIA shall assign the CB an accreditation number allowing it to provide certification services under the COR and shall issue a letter which specifies the certification scope and geographical scope for which the accreditation is granted.
  • B.2.5.2 The CFIA shall assign an accreditation number no later than 14 working days after the accreditation decision.
  • B.2.5.3 The CB shall keep the same accreditation number that they have received originally as long as their accreditation remains valid.

B.3 Monitoring and surveillance of a CB

B.3.1 The CVBs shall be responsible for on- going monitoring of the accredited CB in compliance with the COR requirements including part 13 of the SFCR, ISO 17065, COR Operating Manual, the CFIA directives and memos.

B.3.2 The CVBs shall document their procedures and plans for carrying out periodic on-site assessments and other surveillance activities to verify that the accredited CB continue to fulfill the COR requirements. In cases of extenuating circumstances such as natural disasters, political unrest, the CVBs may modify their surveillance activities.

B.3.3 The surveillance visits shall target the verification of specific CB's certification program elements.

B.3.4 After the initial accreditation, the CVB shall conduct an on-site surveillance of the CB within 12 months of the initial accreditation date.

B.3.5 Prior to conducting an on-site assessment the CVB shall request from the CB updated information, on a date specified by the CVB and review it. The information from the CB shall include the following:

  • B.3.5.1 Changes in the CB information
  • B.3.5.2 Major changes to the CB policies, procedures and protocols
  • B.3.5.3 Information on complaints and appeals
  • B.3.5.4 The most recent internal audit report
  • B.3.5.5 The most recent management review report
  • B.3.5.6 All reported misuses of the Canada organic logo received by the CB
  • B.3.5.7 All changes in the CB certification personnel that are critical to the operation of its certification activities
  • B.3.5.8 Complete list of certified operations in the COR including name, address and phone number of the certified entity, the type of the operation certified (crops, livestock, processing, wild crop). If provided via a directory on the Internet, it is acceptable provide the URL to the directory instead
  • B.3.5.9 Complete list of operations certified to the terms of Canada's organic equivalence arrangements including name, address and phone number of the certified entity, the scope of certification and their locations. If provided through a directory on the Internet, it is acceptable to provide the URL to the directory instead

B.3.6 Over the length of the accreditation cycle, for each surveillance visit, the CVB auditor shall examine a number of files, proportional to the number of the active operators registered with the CB, and based on the numbers shown in the table below.

Table 4: Number of files to be reviewed during each CB surveillance visit
Number of active operators registered with the CB under COR Number of files to be reviewed
Less than 100 Minimum of 5 full reviewsTable note 4 (the number could be increased at the discretion of the CVB)
101 to 240 Minimum of 6 files, 5 of which must be full reviewsTable note 5
241 to 400 Minimum of 8 files, 6 of which must be full reviewsTable note 5
401 to 1000 Minimum of 10 files, 7 of which must be full reviewsTable note 5
More than 1000 Minimum of 12 files, 8 of which must be full reviewsTable note 5

B.3.7 The CVB shall, over the length of the accreditation cycle, conduct witness audits according to the table below as a means of verifying that the accredited CB implements its procedures as written.

Table 5: Number witness audits to be performed over the CB accreditation cycle
Number of active operators registered with the CB under COR Total number of witness audits over the CB accreditation cycle
Less than 100 1 witness audit
101 to 240 2 witness audits
241 to 400 3 witness audits
401 to 1000 4 witness audits
More than 1000 5 witness audits

B.3.8 The CVB shall, over the length of the CB accreditation cycle, conduct verification audits according to the table below to verify the information included in the operators' files.

Table 6: Number of verification audits to be performed over the CB accreditation cycle
Number of active operators registered with the CB under COR Total verification audits over the CB accreditation cycle
Less than 100 1 verification audit
101 to 1000 2 verification audits
More than 1000 3 verification audits

B.3.9 The CVB shall choose the operator for the verification and witness audits. CVB should take into consideration the CB schedule for the upcoming on-site inspections when selecting the operator for witness audits.

B.3.10 During the verification audit, the CVB auditor shall verify, among other matters that:

  • B.3.10.1 The operator has on hand a copy of the CB's certification requirements, as well as any requests for corrective measures submitted to the operator by the CB from the previous CB inspection.
  • B.3.10.2 The certified products/ activities are within the scope of part 13 of the SFCR.
  • B.3.10.3 The inspection report adequately describes the production system.
  • B.3.10.4 The inspection process was able to adequately reveal points of noncompliance with the standard

B.3.11 The CVB auditor shall record the findings from the on-site visit, the witness audit and the results from the verification audits. The format of each report shall be determined by the CVB.

B.3.12 The CVB shall allow the CB 30 working days from receiving the CVB report to submit the specific actions taken or planned to be taken in order to resolve the identified NCs.

B.3.13 When the CVB is satisfied with the CBs corrective actions provided within the specified time frame, the CVB shall inform the CB of the results from the surveillance activities by issuing a letter indicating that the CB continues to maintain its compliance with the COR. The CVB shall send a copy of this letter to the CFIA.

B.3.14 The CVB shall apply one of the enforcement actions as specified in B.7 in the event that NCs have not been addressed satisfactorily within the 30 working days from the receipt of the CVB report.

B.3.15 The CVB may conduct additional assessments as a result of complaints or significant changes that have affected CB operations at the expense of the CB, at any time during the accreditation cycle, or upon its own initiative.

B.3.16 The CFIA may conduct an unscheduled assessment of an accredited CB at any time during the accreditation cycle as a result of complaints or concerns, or at its own discretion.

B.3.17 At the request of the CFIA, the CVBs shall compile, review and submit the annual information from the CB using the CFIA template. The following information will be included in the CB annual report:

  • B.3.17.1 A list of operators in a spreadsheet, including:
    • legal name of the operator
    • address of the operator
    • type of operation (primary, processing, packaging and labelling, attestation) and
    • generic names of the certified products
  • B.3.17.2 Number of new certificates (both organic products and packaging)
  • B.3.17.3 Number of annual inspections and un-announced inspections
  • B.3.17.4 Number of nonconformities and samples taken
  • B.3.17.5 Number of complaints

B.3.18 At any time during the accreditation cycle the CVB may accept request from the CB to extend the scope of accreditation. The CVB shall have documented procedure to address such request. The CVB shall recommend to the CFIA scope expansion when the CVB is confident that the CB has fulfilled the requirements for accreditation.

  • B.3.18.1 Geographical scope and Accreditation category addition
    • B.3.18.1.1 The CVB shall review the CB request/application and supporting documents confirming availability and the training of the verification officers (VO).
    • B.3.18.1.2 The CVB does not need to conduct a witness audit (WA) if there are no operators at the time of the application, however the CVB shall confirm the expertise and knowledge of the CB personnel involved in the certification process.
    • B.3.18.1.3 The CVB shall send to the CFIA a recommendation letter to extend the CB's geographical scope/accreditation category along with the results from the review.
    • B.3.18.1.4 The CFIA will make the final decision and will amend the accreditation letter accordingly.
    • B.3.18.1.5 During the next planned CB office audit, the CVB auditor shall verify how the new scope/category is managed by the CB (interview with key personnel, review of the first operator's file, etc.).
    • B.3.18.1.6 The CVB shall schedule a WA in the new geographical location/accreditation category as soon as the CB has an operator.
  • B.3.18.2 Addition of aquaculture standard
    • B.3.18.2.1 The CVB shall review the CB request/application and supporting documents.
    • B.3.18.2.2 The CVB shall be satisfied with the expertise of the CB staff that is involved in the aquaculture standard.
    • B.3.18.2.3 The CVB is not required to conduct a WA or have a meeting with the CB if:
      • B.3.18.2.3.1 the CB is already accredited for aquaculture standard outside COR
      • B.3.18.2.3.2 the CB is already accredited for CAN/CGSB-32.310 to certify wild collection and they want to add CAN/CGSB-32.312 for seaweed
      • B.3.18.2.3.3 the CB is already accredited for CAN/CGSB-32.310 to certify processed products and want to add CAN/CGSB-32.312 for processing of aquaculture products
    • B.3.18.2.4 In all the other cases (not covered by B.3.18.2.3) the CVB shall schedule and conduct a WA on the new standard as soon as the CB has an operator.
    • B.3.18.2.5 The CVB shall send to the CFIA a recommendation letter to add the aquaculture standard along with the results from the review.
    • B.3.18.2.6 The CFIA will make the final decision and will amend the accreditation letter accordingly.
    • B.3.18.2.7 During the next planned CB office audit, the CVB auditor shall verify how this new scope is managed by the CB (interview with key personnel, review of the first operator's file, etc.).

B.4 Reassessments of a CB

B.4.1 The CB shall apply for reassessment according to the CVB's own procedure to allow the CVB to complete all assessment activities before the accreditation expires.

B.4.2 In the event of reassessment the CVB shall follow the requirements for initial assessment outlined in sections B.2.1 and B.2.2.

B.4.3 Following the reassessment, the CVB shall follow the requirements for accreditation recommendation outlined in section B 2.3.

B.4.4 The CB shall continue to be responsible for providing access to records, files and other related documentation to the CVB and the CFIA during reassessment and continued accreditation oversight activities.

B.5 Appeals of CFIA accreditation decision by a CB

B.5.1 Any applicant CB has the right to request that the CFIA review the accreditation decision. The appeal against the decision shall be made within 30 days of notification of that decision pursuant to SFCR section 362.

B.5.2 The appeal shall be filed in writing along with all the necessary supporting documents.

B.5.3 The CFIA shall give the final decision on the appeal. The decision of the CFIA in this regard shall be final.

B.6 Appeals of CVB recommendation decision of a CB

B.6.1 The CVB shall document their own appeal policy and procedure to deal with appeals against final recommendations made by the CVB to the CFIA and also against specific CVB decisions.

B.6.2 The CVB policies shall address appeals of the following decisions as minimum:

  • B.6.2.1 Decision whether to proceed with a visit
  • B.6.2.2 Decision regarding any additional visit
  • B.6.2.3 Decision to terminate an evaluation process
  • B.6.2.4 Decision whether to recommend the reduction of accreditation scope to CFIA

B.7 Reduction of scope, suspension and cancellation of a CB

B.7.1 The CVB shall follow their documented procedures for identification and management of NCs.

B.7.2 The CVB shall apply 1 or more of the following enforcement actions in an event the NCs are not addressed within the specified time frame:

  • B.7.2.1 Recommend to the CFIA to reduce the accreditation scope
  • B.7.2.2 Submit to the CFIA report for grounds for suspension of the CB

B.7.3 The CVB shall submit a report for grounds for suspension in any of the following cases:

  • B.7.3.1 the CB has failed to effectively implement the corrective actions or where the assessment reveals that the CB has failed to effectively implement the corrective actions. related to conditions that have previously been considered fulfilled
  • B.7.3.2 if the CB does not have any operators after 2 consecutive surveillance assessments in an accreditation cycle

B.7.4 The CVB shall provide the written report to the CB and the CFIA describing the grounds for suspension and the CVB shall allow the CB 15 working days to take corrective action as per paragraph 364(2)(a) of the SFCR.

B.7.5 The CVB may grant 1 extension period upon written request from the CB supported by justification as per subsection 364(3) of the SFCR. The length of the extension period is at the discretion of the CVB but should not be longer than 60 working days.

B.7.6 In the case when the CVB is satisfied that the CB has resolved the issues that were grounds for suspension within the time allowed, the CVB shall notify the CFIA and recommend continuation of accreditation or re-accreditation.

B.7.7 In the case when the CVB is not satisfied with the CB's corrective actions, the CVB shall recommend suspension to the CFIA.

B.7.8 The CFIA shall issue the notice of suspension and the date on which it takes effect.

B.7.9 The CB has 15 days after the day the accreditation was suspended to submit their list of operators as per subsection 364(5) of the SFCR.

B.7.10 The CB has 30 days after the day the accreditation was suspended to take corrective action as per paragraph 365(1)(a) of the SFCR.

B.7.11 The CB shall submit their corrective action to the CVB for review and assessment. The CVB shall determine the acceptability of the corrective action plan within 10 working days.

B.7.12 In the case when the CVB is satisfied with the CB's corrective actions, the CVB shall recommend lifting the suspension to the CFIA as per subsection 364(6) of the SFCR.

B.7.13 In the case when the CVB is not satisfied with the CB's corrective actions or the CB did not submit corrective actions within the time allowed, the CVB shall recommend to the CFIA cancellation of accreditation as per subsection 365(1) of the SFCR.

B.7.14 The CFIA shall issue a notice in writing on the grounds for cancellation to the CB and give the CB opportunity to be heard as per subsection 365(2) of the SFCR. The CFIA shall allow 20 working days to the CB for the opportunity to be heard.

B.8 Complaints against CB

B.8.1 The CVB shall document its policies and procedures that outline how complaints related to accredited CB and their operators are handled by the CVB.

B.8.2 The CVB shall acknowledge receipt of any complaint received from the CFIA within 5 working days.

B.8.3 The CVB shall begin the investigation of the complaint as per its own procedures, or forward the complaint to the appropriate CB for investigation if the complaint is on a certified organic product, producer or CB personnel.

B.8.4 When forwarding complaints to the appropriate CB, the CVB shall ensure the complainant's confidentiality is maintained.

B.8.5 Within 20 working days, the CVB shall inform the CFIA of the following:

  • the status of the complaint
  • what actions have or will be taken to resolve the complaint
  • the expected timeline for resolution of the complaint
  • requests for additional information as required

B.8.6 The CVB shall endeavour to close all complaints received in a timely manner. Upon closure of the complaint the CVB shall provide the CFIA with the following:

  • confirmation that the CVB considers the complaint adequately closed
  • a summary of the actions the CVB/CB took to close the complaint
  • any important follow-up information (for example, unannounced audit to verify, grounds for suspension, etc.)

B.8.7 The CFIA shall inform the CVB that the complaint is considered closed once the CFIA has reviewed the information provided and determines that no additional information is required.

B.8.8 In case that the complaints cannot be resolved between the CB and the CVB, the CFIA is the final step to hear the issue.

B.9 Records maintained by the CVB

B.9.1 The CVB shall maintain records on the CB they recommended for accreditation to demonstrate that the requirements for accreditation, including competence, have been effectively fulfilled. The records to be maintained include:

  • B.9.1.1 general features of the CB, including corporate entity, name, addresses, legal status and human and technical resources
  • B.9.1.2 general information concerning the CB such as its activities, its relationship in a larger corporate entity if any, and addresses of all its physical location(s) to be covered by the scope of accreditation
  • B.9.1.3 clearly defined scope of accreditation
  • B.9.1.4 a contract to fulfill the requirements for accreditation and the other obligations of the CB, including submitting all necessary documentation requested in section B.11
  • B.9.1.5 a description of the conformity assessment services that the CB undertakes, and a list of standards, methods, or procedures for which the CB seeks accreditation, including limits of capability where applicable
  • B.9.1.6 a copy (on paper or in electronic form) of the quality manual of the CB, and relevant associated documents and records (refer to section B.11)

B.10 CVB agreement with the CB

B.10.1 The CVB shall prepare and implement surveillance agreement (contract) between the CB and CVB that outlines the rights and duties of the CB and the CVB which shall be signed by the CB and the CVB.

B.10.2 The CVB shall provide a sample of this agreement as part of the application package provided to the CB.

B.11 CB documents required for accreditation application (except the cases when a CB changes their CVB)

This section lists those documents or information that the applicant CB is to submit to the CVB as part of its initial and reassessment application as a CB.

B.11.1 Documents pertaining to the CB

  • B.11.1.1 The corporate charter
  • B.11.1.2 The corporate structure showing graphically and quantitatively relations of control by shareholders, companies or other groups for the organization
  • B.11.1.3 The general by laws
  • B.11.1.4 A list of directors, comprising:
    • members of the board of directors (including specific function, duration of mandate, and affiliation)
    • board members of a sponsoring organization (if applicable)
  • B.11.1.5 The addresses of all locations where the firm does business and summary of activities from each location
  • B.11.1.6 A copy of the compliance mark (body's name such as it appears on the label or certified product) and any property rights related to it
  • B.11.1.7 In the case of CB already accredited by an official organization (for example, another accreditation body), a copy of the accreditation certificate for the CB from the other organization

B.11.2 Description of decision making structures

  • B.11.2.1 A description of individuals or internal bodies making decisions covering:
    • product certification
    • appeals
    • brand name control (certifying body's name and logo)
    • along with their mandate, their procedures, and the manner in which they are designated
  • B.11.2.2 A description of sharing of responsibilities between head office and affiliates (if applicable)
  • B.11.2.3 An organization chart related to the general administration of the program including names of persons occupying managerial positions in both Head Office and Affiliates (if applicable)

B.11.3 Information on CB's operations

  • B.11.3.1 Copy of the latest annual financial statements, including balance sheet, revenues and expenses
  • B.11.3.2 List of countries, provinces or states in which the body is carrying out certification activities
  • B.11.3.3 Complete list of all firms including the name and address of each 1 to which the body has granted a compliance certificate, in the 1 or more fields for which it has applied for accreditation:
    • a compliance certificate for the certified products
    • a certificate of recognition for any inputs or services
  • B.11.3.4 Copy of the Board of Director's latest annual report to members or stockholders

B.11.4 Standards, policies and technical procedures (quality manual)

  • B.11.4.1 The quality manual related to the certification program
  • B.11.4.2 Templates of inspection questionnaires used by VO
  • B.11.4.3 Templates of inspection reports
  • B.11.4.4 List of documents included in the file for each operator having requested certification

B.11.5 CB human resources management

  • B.11.5.1 A complete list of certification employees including the status and position held by each one.
  • B.11.5.2 A copy of the standard contract with certification employees
  • B.11.5.3 The selection criteria for persons making certification decisions and persons in charge of overseeing people who make certification decisions
  • B.11.5.4 The name of persons or list of the members of the internal body (committee, etc.) assigned either to make certification decisions or to oversee those who make them (with their experience or specific training)
  • B.11.5.5 The selection criteria for the VOs
  • B.11.5.6 Copy of standard contract between the CB and VO
  • B.11.5.7 Complete list of VOs (including their training and years of experience, their commercial or financial affiliation)
  • B.11.5.8 A copy of the standard contract used with any other type of subcontractors (if applicable)

B.11.6 Information material and forms forwarded to an applicant

  • B.11.6.1 A detailed fee schedule for the certification services offered
  • B.11.6.2 Copies of information documents about the certification program
  • B.11.6.3 Copy of the application forms to be filled by applicants
  • B.11.6.4 Copies of production or preparation compliance plan forms to be filled annually by applicants

B.11.7 Documents concerning rights and obligations of certified operators

  • B.11.7.1 Contract(s) to be signed by certification applicants, regulating the use of marks of compliance (licenses)
  • B.11.7.2 Copy of the certificate issued by the CB in accordance with the COR and equivalency arrangement (if applicable)
  • B.11.7.3 Electronic copy of a label using the name of the CB and Canada Organic Logo

B.12 Requirements when a CB changes CVB under the COR

This section is applicable to the situation where a CFIA accredited CB chooses to change their CVB.

B.12.1 Requirements on CB

  • B.12.1.1 The CB shall submit an application form to another designated CVB and notify the current CVB of the decision to change
  • B.12.1.2 The CB shall provide all supporting documents as requested by the receiving CVB
  • B.12.1.3 The CB shall pay the application fees determined by the receiving CVB
  • B.12.1.4 The CB shall cease use of the previous Accreditation letter and destroy it.

B.12.2 Requirements on sending CVB

  • B.12.2.1 The CVB shall inform the CFIA immediately when a CB notifies them of their intention to change CVBs
  • B.12.2.2 The CVB shall provide to the CFIA the results from the last CB audit (copy of the most recent audit reports, associated NCs status and any outstanding issues)

B.12.3 Requirements on receiving CVB

  • B.12.3.1 The CVB shall send acknowledgement of receipt to the applicant CB within 10 working days and shall notify the CFIA immediately about the application
  • B.12.3.2 After CFIA reviews the documentation provided by the sending CVB, and after discussion between the receiving CVB and the CFIA, the receiving CVB shall:
    • B.12.3.2.1 Accept the compliance status of the CB with further oversight activities as agreed by the CFIA and the receiving CVB
    • B.12.3.2.2 Send a recommendation letter to the CFIA to confirm that the CVB will take over the monitoring of the CB and to request amendment to the current CB accreditation letter
    • B.12.3.2.3 Take over the monitoring of the CB from the point in the accreditation cycle established by the sending CVB

B.12.4 Requirements on CFIA

  • B.12.4.1 The CFIA shall verify the CB status with the sending CVB and shall request the CVB provide to the CFIA, the results from the last CB audit (copy of the most recent audit reports, associated NCs status and any outstanding issues)
  • B.12.4.2 The CFIA shall review the documentation provided by the sending CVB and shall discuss the CB status with the receiving CVB to ensure that the change is smooth and without negative impact. The CFIA shall discuss with the receiving CVB the outstanding requirements of the accreditation cycle
  • B.12.4.3 The CFIA shall issue a revised Accreditation letter to the CB after receiving a recommendation letter from the receiving CVB
  • B.12.4.4 The CFIA shall change only the name of the CVB on the revised Accreditation letter
  • B.12.4.5 The CFIA shall request the CB to return to the CFIA the previous Accreditation letter once they receive the revised letter

B.13 Requirements for voluntary withdrawal of a CFIA accredited CB under the COR

This section is to address the situation when a CB accredited by CFIA wishes to withdraw voluntarily its CFIA accreditation under COR.

B.13.1 Requirements on CB

  • B.13.1.1 The CB shall send a written notice to the CVB that monitors the CB activities under COR
  • B.13.1.2 The CB shall submit to the CVB the list of holders of certifications and a list of pending applications for certification as per sub section 364(5) from part 13 of the SFCR
  • B.13.1.3 The CB shall notify the holders of certifications within 3 months after the CB has sent the written notice to the CVB to give them sufficient time to find another certification body
  • B.13.1.4 The CB shall surrender the CFIA accreditation letter before it expires

B.13.2 Requirements on CVB

  • B.13.2.1 The CVB shall acknowledge the receipt of the CB notification within 10 working days
  • B.13.2.2 The CVB shall notify the CFIA immediately when a CB has indicated its intention to withdraw its accreditation
  • B.13.2.3 The CVB shall submit a recommendation letter to the CFIA for decision on the withdrawal of accreditation
  • B.13.2.4 The CVB shall ensure that any reference to the COR on the CB's website and on CB promotional materials is removed

B.13.3 Requirements on CFIA

  • B.13.3.1 The CFIA shall review the CVB recommendation letter
  • B.13.3.2 The CFIA shall send, upon recommendation from the CVB, a notice of cancellation to the CB as per subsection 365(1) of the SFCR
  • B.13.3.3 The CFIA shall remove the CB name from the list of the CFIA accredited certification bodies on the date of the accreditation cancellation.

B.14 Requirements when a CB goes out of business

This section is to address the situation when a CB accredited by CFIA goes out of business.

The term "going out of business" is broad and includes a spectrum of financial states of a CB. One end of the spectrum could include a CB that is experiencing financial difficulty, but is still operational and able to meet their financial obligations, but may become insolvent in the future. The other end of the spectrum could include a CB that has declared bankruptcy. Also included in between the 2 ends of the spectrum might be CBs that are insolvent but not yet bankrupt and who may file a proposal to avoid bankruptcy.

B.14.1 Requirements on CB

  • B.14.1.1 The CB shall notify immediately its CVB in cases where it plans to stop certifying organic products or it may become unable to continue to certify organic products.
  • B.14.1.2 The CB shall provide to the CVB the list of holders of certifications and the list of pending applications for certification as per subsection 364(5) of part 13 of the SFCR.
  • B.14.1.3 The CB shall not accept new applications for certification during this period of financial uncertainty but shall make every effort to complete the certification process of the existing applicants.

B.14.2 Requirements on CVB

  • B.14.2.1 The CVB shall request the CB to provide the list of holders of certifications and the list of pending applications for certification as per subsection 364(5) of part 13 of the SFCR when the CVB becomes aware that the CB is planning to stop certifying organic products or it may become unable to continue to certify organic products.
  • B.14.2.2 The CVB shall notify the CB of its inability to accept new applications if the CVB has determined that the CB is planning to stop certifying organic products or it may become unable to continue to certify organic products.
  • B.14.2.3 The CVB shall monitor the certification activities of this CB to ensure that it makes every effort to complete any ongoing certifications.
  • B.14.2.4 The CVB shall work with the CFIA and the CB to inform the operators at the appropriate time.
  • B.14.2.5 The CVB shall send a recommendation for accreditation cancellation to the CFIA if the CB ceases to conduct business.

B.14.3 Requirements on CFIA

  • B.14.3.1 The CFIA shall cancel the accreditation of the CB under section 365 of part 13 of the SFCR in cases when the CB ceases to conduct business.
  • B.14.3.2 The CFIA and the CVB shall work together to ensure that all the proper actions are taken as per part 13 of the SFCR.

B.14.4 Requirements on the operators

  • B.14.4.1 It the responsibility of the operator to apply to a new CB within the time prescribed in subsection 344(3) of part 13 of the SFCR and follow the steps as described in section C.2.5 of the COR Manual if they wish to continue their certification.

B.15 Requirements when a CVB can conduct remote audits at CBs

This section outlines the criteria that should be considered by a CVB when scheduling and conducting a remote audit at a CFIA accredited CB.

The "remote audit" is an audit that uses electronic means to remotely obtain evidence to determine the extent of conformity to the audit criteria.

A remote audit can be "partial" when only some parts of the audit (for example operator file checks) are conducted remotely or "full" when the whole audit (all checks) is completed remotely.

  • All audits conducted by CVBs may be performed remotely in case of:
    • climactic or socio-economic conditions are unfavorable and/or make them impossible, (for example for safety reasons: pandemics, country at war, conflict or instability, extreme weather condition)Footnote 6
  • In normal conditions B.15.1.1 applies

B.15.1 Eligibility

B15.1.1 The CVBs may conduct the following audits remotely:

  • surveillance audit
  • additional assessment - as a result of a complaint
  • follow-up audit - to verify implementation of a corrective action following a NC

B15.1.2 The CVBs shall not conduct the following audits remotely:

  • initial audit
  • reassessment audit
  • witness audit
  • verification audit

B.15.2 Requirements on CVB

B.15.2.1 The CVB may consider conducting a remote audit if the CB has the capacity and technical resources (for example good internet connection) to be assessed remotely with secure access to the CB intranet for reviewing documentation in any of the following possible situations:

  • the CB has a good certification system in the previous 2 years (for example in relation to the number of NCs, complaints, appeals)
  • CB system is not complex (for example number of operators, type of certification, grower group)
  • additional CB offices with no key activities
  • documentation review and interviews are sufficient to make a decision on a minor change in current accreditation

B.15.2.2 The CVB shall define the means of on-line communication ( for example provide information on the audit techniques) and make a compatibility test of the communication platform before confirming a remote audit.

B.15.2.3 The CVB shall determine whether the remote audit is acceptable and possible to conduct and will notify the CB in writing.

B.15.2.4 The CVB shall develop and share with the CB an audit plan with specific timetables (for the CB and the CVB). The CVB shall confirm with the CB whether this plan is acceptable.

B.15.2.5 The CVB shall specify whether the CB must be online or whether the auditor works alone (for example documentary analysis, preparation for the closing meeting) in the audit plan or during the opening meeting.

B.15.2.6 The CVB shall not conduct more than 2 consecutive full remote audits at a specific CB.

B.15.2.7 The CVB shall not schedule a remote audit at a CB with recurring and numerous issues (for example noncompliance, notice of intention to suspend, complaints, appeals).

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