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FINAL Comment on Canadian Regulation 11-16-06 - Organic Trade Association
Organic Trade Association
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FINAL Comment on Canadian Regulation 11-16-06

 

November 16, 2006

 

Dr. Bashir Manji,

Canadian Food Inspection Agency

59 Camelot Drive

Ottawa, Ontario K1A 0Y9                                                    

 

RE: Canada Gazette I, Volume 140, No. 35, September 2, 2006, Organic Products

Regulations 

 

Dear Dr. Manji,

 

The Organic Trade Association, founded in 1985, is North America’s only business membership association focused exclusively on the organic food, fiber and personal care products sector. OTA represents members operating in Canada as farmers and ranchers, processors, distributors and retailers.  The mission of the Organic Trade Association is to promote and protect the growth of organic trade to benefit the environment, farmers, the public and the economy.  OTA envisions organic products becoming a significant part of everyday life enhancing people’s lives and the environment.

 

OTA is pleased to have the opportunity to review and comment on [see attached] the proposed national Canadian organic regulation, having supported and participated in its development. OTA applauds the Canadian Food Inspection Agency and Agriculture and Agri-Food Canada for consulting with the organic producers, manufacturers, retailers and certifiers to develop this proposed regulation.

 

OTA believes that it is vital that a strong and mutually respectful working relationship is established between the government bodies that develop and enforce regulations and the industry that must work under those regulations. We have already been working to establish that relationship and offer OTA’s comments in furtherance of that objective.

 

OTA agrees that an effective regulation will “facilitate international market access, provide protection to consumers against deceptive and misleading labelling practices and support the further development of the domestic market,” as stated in the Introduction to the Organic Products Regulations.

 

OTA also agrees with the Introduction’s statement: “Organic agricultural production is a management system designed to produce crops and livestock in an ecologically stable way. Soil fertility is maintained, animals are raised in a manner appropriate to their behavioural requirements and synthetic fertilizers and pesticides are not used.”

 

However, because organic certification is based on the methods used in the aforementioned management system of an agricultural, processing or handling operation, and is not based on the end product, OTA has recommended changes to each mention of “products” in the regulation to clarify the object of organic certification.

 

OTA appreciates the reason that the regulation references, rather than includes CAN/CGSB-32.310, Organic Production Systems — General Principles and Management Standards, CAN/CGSB-32.311, Organic Production Systems — Permitted Substances List; and the Organic Quality Management Systems Manual. This allows for somewhat easier amendment of those documents to reflect the evolution of the organic production, manufacturing and distribution environments.

 

The proposed regulation works in conjunction with The Canada Agricultural Products (CAP) Act, CAN/CGSB-32.310, Organic Production Systems — General Principles and Management Standards, CAN/CGSB-32.311, Organic Production Systems — Permitted Substances List; and the Organic Quality Management Systems Manual. It is important that the organic sector lend its expertise to the standard, permitted substances list and Organic Quality Management Systems Manual, as those documents flesh out the details of the regulation. 

 

Throughout the consultation period leading to publication of this regulation, the government has assured the organic industry that the system would be “evergreen”, developing via a public-private partnership. We understand that the amendment process for the standard and permitted substances list is managed by the Canadian General Standards Board.  OTA members believe it is important that government spell out the process and schedule for amending the Organic Quality Management Systems Manual.

 

As OTA has seen in the United States, there can be a strong and effective relationship established by regulation between the public and private sectors.  The U.S. National Organic Program and its industry-based National Organic Standards Board (NOSB) cooperate to effect change that positively influences the industry and consumers, and OTA believes a public/private system will deliver some of the same benefits in Canada. 

 

Similarly, the Canadian system requires a board or council to whom the government must be accountable. The Canadian Organic Regulation Council (CORC) has been proposed to provide recommendations to the CFIA and share authority over the directives contained in the Organic Quality Management Systems Manual. While an advisory council that simply gives feedback to the CFIA may be of value to the industry and consumers, that value is limited if the council has no stated role in the regulation, and the OTA’s comments recommend to government that it consider ways to strengthen the CORC. 

 

OTA is certain that an ISO model can be a guiding principle to develop a system of public-private consultation to ensure ongoing improvement of the Organic Quality Management Systems Manual. OTA will submit comment on the Manual regarding an organic industry advisory body to ensure private sector involvement in the management of Canada’s organic regulation.

 

OTA’s proposed revisions to Sections 9, 10 and 11 in the regulation will enable CFIA to secure better control information, with less delay and paperwork. The proposed revisions will give Canada a more effective system to facilitate negotiation for international recognition and/or equivalency.

 

OTA has extensive experience with organic regulatory issues in the United States and international markets. The association hopes its specific comments that are attached to this letter will help to tighten the regulatory framework, while enhancing conditions for organic trade. Please note that the OTA comments are presented embedded in the proposed Regulation, in a slightly larger and different typeface than the Regulation text.

 

Thank you for the opportunity to work with CFIA and the organic community in Canada on this important initiative.

 

Sincerely,

 

 

Helene Bouvier                Dag Falck                 Stephanie Wells

Vice President - Canada  Member of the Board  OTA Canada Representative 

 

For the Organic Trade Association

 


 

 

Organic Trade Association Comments

on the

CANADA ORGANIC PRODUCTS REGULATIONS

 

(Please note that the OTA comments are presented embedded in the proposed Regulation, in a slightly larger and different typeface than the Regulation text.)

 

 

Re: Canada Gazette I, Vol. 140, No. 35 — September 2, 2006

 

Organic Products Regulations

 

Statutory authority

 

Canada Agricultural Products Act

 

Sponsoring agency

 

Canadian Food Inspection Agency

 

 PROPOSED REGULATORY TEXT

 

Notice is hereby given that the Governor in Council, pursuant to section 32 (see footnote a) of the Canada Agricultural Products Act (see footnote b), proposes to make the annexed Organic Products Regulations.

 

 Interested persons may make representations with respect to the proposed Regulations within 75 days after the date of publication of this notice. All such representations must cite the Canada Gazette, Part I, and the date of publication of this notice, and be addressed to Bashir Manji, Canadian Food Inspection Agency, 59 Camelot Drive, Ottawa, Ontario K1A 0Y9.

 

 Persons making representations should identify any of those representations the disclosure of which should be refused under the Access to Information Act, in particular under sections 19 and 20 of that Act, and should indicate the reasons why and the period during which the representations should not be disclosed. They should also identify any representations for which there is consent to disclosure for the purposes of that Act.

 

 Ottawa, August 25, 2006

 

 MARY O'NEILL

Assistant Clerk of the Privy Council

 

ORGANIC PRODUCTS REGULATIONS

 

INTERPRETATION

 

 1. The following definitions apply in these Regulations.

 

 "accreditation body" means a body that has entered into an agreement with the Agency under subsection 14(1) of the Canadian Food Inspection Agency Act to administer certain tasks, including assessing, recommending and monitoring the accreditation of certification bodies. (organisme d'accréditation)

 

 "Act" means the Canada Agricultural Products Act. (Loi)

 

 "Agency" means the Canadian Food Inspection Agency established by section 3 of the Canadian Food Inspection Agency Act. (Agence)

 

 "certification body" means a body that is accredited as a certification body in accordance with section 5. (organisme de certification)

 

 "organic product" means an agricultural product that has been certified as organic in accordance with these Regulations. (produit biologique)

= = = = = =

Amend this definition of “organic product” to read:

"organic product" means an agricultural product that has been produced and handled by an operation certified in accordance with these Regulations. In the case of a multi-ingredient product, 95 percent or more of its ingredients must have been certified as organic in accordance with these Regulations in order for it to be labelled “Organic”. A multi-ingredient product with 70 percent to 95 percent of its ingredients certified as organic in accordance with these Regulations may be labelled “Made with organic_______”.  (produit biologique)

 

Rationale: OTA believes the definition of “organic product” must reflect the fact that organic certification refers to certification of the methods used in an agricultural, processing or handling operation, and not to the end product.  Throughout this regulation, we accordingly recommend that any reference to certification of a product be revised to reflect the fact that it is always the operation that is certified, not the end product.

 

OTA also recommends that the Regulation be clear about the permitted identification of multi-ingredient products.

= = = = = =

Amend 1. to include:

 

Quality Management System (Système de management de la qualité)

Coordinated activities to direct and control an organization with regards to quality.

(Source: ISO 9000:2005(E))

 

“Organic Quality Management System Manual”

Means a manual established and maintained by the Canada Food Inspection Agency, in consultation with an organic industry advisory body, which defines and documents the quality management system, including mandatory procedures and instructions for effective implementation and enforcement of the National Organic Regulations. (COO)

 

Rationale: The Organic Quality Management System Manual and its accompanying Annexes elaborate the detailed procedures and requirements for certified operations governed by this regulation. The Organic Quality Management System Manual should be referenced in this regulation along with procedures for the Manual’s amendment.

NOTE regarding an industry advisory body: Throughout the development of this Regulation, representatives of Agriculture & Agri-Foods Canada and the Canadian Food Inspection Agency have told the organic sector that this regulation would be an "evergreen" or evolving document, which would be "enabling" to allow for expanded scope and improved production techniques. The government representatives said the regulation and its elements would be maintained via a "public/private partnership" to ensure that organic sector expertise would contribute to the continuous improvement of Canada’s organic programme.

We believe the Canadian Organic Regulation should include language to reflect this joint responsibility.

The government strongly urged the organic sector to organize a representative group to work with government on regulatory issues. To that end, the organic sector is establishing the Canadian Organic Regulatory Council (CORC). OTA supports the establishment of CORC (and its subcommittees) to be a representative body for the organic producers, processors, handlers, exporters/traders, retailers and certifiers. Its members should be democratically elected, one from each province and territory and one from national business associations, with broad representation of the organic sector. CORC representatives must have the expertise needed for continued improvement and expansion of Canada's organic regime.

= = = = = =

 PART 1

 

 ORGANIC PRODUCTS

 

 2. (1) Only organic products as defined in section 1 may use the logo set out in the schedule or the designations "Canada Organic" and "Biologique Canada".

 

 (2) Only organic products as defined in section 1 shall be marketed in interprovincial or international trade.

= = = = = =

Note: 2.1 as written, does not limit the use of the “Canada Organic” and “Biologique Canada” designations to products grown within Canada. OTA’s position is that any certified product produced in compliance with these Regulations and CAN/CGSB-32.310, the Organic Production Systems — General Principles and Management Standards and CAN/CGSB-32.311, Organic Production Systems — Permitted Substances List should be permitted to be labelled with the logo set out in the schedule or the designations "Canada Organic" and "Biologique Canada".

 

Note: 2.1 refers to the definition of  “organic products” as defined in section 1. OTA has stated that the definition in section 1 should be amended to read:

"organic product" means an agricultural product that has been produced and handled by an operation certified in accordance with these Regulations. In the case of a multi-ingredient product, 95 percent or more of its ingredients must have been certified as organic in accordance with these Regulations.

 

Rationale: OTA supports limiting the use of the “Canada Organic” and “Biologique Canada” designations to products that contain 95% or more ingredients certified as organic in accordance with these Regulations and CAN/CGSB-32.310, the Organic Production Systems — General Principles and Management Standards and CAN/CGSB-32.311, Organic Production Systems — Permitted Substances List.

= = = = = =

 

 3. The logo set out in the schedule and the designations "Canada Organic" and "Biologique Canada" are agricultural product legends.

 

 PART 2

 

 CERTIFICATION BODIES

 

 Application for Accreditation

 

4. Any person who wishes to be accredited as a certification body shall apply for the accreditation in writing to an accreditation body and shall undergo an evaluation approved by the Agency that tests their knowledge of the principles and practices respecting organic certification.

= = = = = =

Amend 4. to read:

 

4. Any person who wishes to be accredited as a certification body shall apply for the accreditation in writing to an accreditation body and shall undergo an evaluation approved by the Agency that tests their knowledge of the principles and practices respecting organic certification. The accreditation of certification bodies shall be implemented in accordance with the most recent version of Annex 2 of the Organic Quality Management Systems Manual.

 

Rationale: It is important that the provisions of the Organic Quality Management Systems Manual be referenced wherever applicable, to ensure that consistent accreditation and certification procedures are implemented with appropriate oversight by the duly appointed industry stakeholder group.

= = = = = =

 

 Accreditation

 

5. On the recommendation of an accreditation body, the Agency shall accredit the applicant as a certification body and provide the applicant with an accreditation number.

= = = = = =

Amend 5. to read:

5. On the recommendation of an accreditation body, the Agency shall accredit the applicant as a certification body.

 

Rationale: It is not clear that an accreditation number for certifiers will offer significantly improved control for traceability. If an accreditation number is required, OTA recommends that the number become a unique and constant number for the certification body. Creating a system that changes accreditation numbers will create an undue burden on producers and will result in unnecessary packaging and labelling expenses.

= = = = = =

 

 6. If the accreditation body refuses to recommend the accreditation of the applicant, the accreditation body shall send a notice to the applicant, by registered mail, stating the reasons for the decision and advising the applicant of their right to request that the Agency review the decision. The accreditation body shall also send a copy of the notice, including the reasons, to the Agency.

 

 Suspension and Cancellation

 

7. (1) Subject to subsection (2), on the recommendation of the accreditation body or on the Agency's own decision, the Agency shall suspend the accreditation of a certification body if the certification body fails to comply with any provision of the Act or these Regulations.

 

 (2) No accreditation may be suspended unless the Agency has

 

 (a) notified the certification body that there are grounds for suspension;

 

 (b) provided the certification body with a copy of a report that specifies the grounds for suspension, the required corrective measures and the period within which those measures must be implemented to avoid suspension; and

 

 (c) sent a notice of suspension to the certification body.

 

 (3) The suspension of an accreditation remains in effect until the required corrective measures have been implemented and verified.

 

 (4) On the recommendation of the accreditation body or on the Agency's own decision, the Agency shall cancel the accreditation if

 

 (a) the certification body has not implemented the required corrective measures within the specified period or within a longer period provided under subsection (5); or

 

 (b) the application made under section 4 contains false or misleading information.

 

 (5) If the certification body has not implemented the required corrective measures or their implementation is not possible within the specified period, the certification body may obtain from the Agency a longer period to implement those measures.

 

 (6) No accreditation may be cancelled unless the Agency has

 

 (a) advised the certification body of an opportunity for it to be heard in respect of the cancellation and the certification body was given that opportunity either orally or in writing; and

 

 (b) sent a notice of the cancellation to the certification body.

 

 PART 3

 

 ORGANIC CERTIFICATION

 

 Application for Organic Certification

 

8. (1) Every person who wishes to have an agricultural product certified as an organic product shall apply for that certification in writing to a certification body.

 

 (2) The application shall contain:

 

 (a) the name of the agricultural product in respect of which the organic certification is being applied for;

 

 (b) in the case of an agricultural product containing more than one agricultural product, a statement setting out the percentage of each of them that are organic products;

= = = = = =

Amend Section 8.1 through 8.2. (b) to read:

8. (1) Every person who wishes to identify an agricultural product as organically produced shall apply for certification of the applicable production or handling operation in writing to a certification body.

 

(2) The application shall contain:

 

 (a) the name of the operation for which the organic certification is being applied;

 

 (b) a current list of the categories of organic products produced at the time of application by the operation seeking certification;

 

Rationale: OTA knows that the original 8.2 (b) is only one of many pieces of information the applicant must supply to a certification body. That level of detail can be covered in the Organic Quality Management System Manual. Furthermore, providing the percentage of each of the ingredients in a multi-ingredient product is tantamount to releasing the recipe, which is proprietary information. Operators understand that they must show recipes or formulations to the inspector who audits their certification application. We again emphasize that the end product is not the object of organic certification; certification is based on the methods used in an agricultural, processing or handling operation.

= = = = = =

 

 (c) a statement setting out the substances used in the production of the agricultural product and the manner in which those substances are used; and

 

 (d) a report setting out in detail the methods of production used in the production of the agricultural product and the control mechanisms in place to ensure that those methods comply at all times with the standards set out in the most recent edition of CAN/CGSB-32.310, the Organic Production Systems — General Principles and Management Standards.

= = = = = =

Amend 8.2 (d) to read:

 

(d) an organic system plan setting out in detail the methods of production used in the production of the agricultural product and the control mechanisms in place to ensure that those methods comply at all times with the standards set out in the most recent editions of CAN/CGSB-32.310, the Organic Production Systems — General Principles and Management Standards and CAN/CGSB-32.311, Organic Production Systems — Permitted Substances List.

 

Rationale : OTA suggests that “organic system plan” is a more accurate description that reflects the basic principles of organic production as well as prevailing international norms.

= = = = = =

 

 International Marketing

 

9. (1) A person who wishes to market an organic product in export trade shall obtain from a certification body a certificate attesting that the product is an organic product.

 

 (2) The application shall be in writing and shall include evidence that the product has been certified as an organic product.

 

 (3) The certification body shall issue the certificate if it obtains evidence that the product in respect of which the application was made is an organic product.

= = = = = =

Amend 9. to read:

 

9. (1) A person who wishes to market a product labelled organic in export trade shall obtain from a certification body a certificate attesting that the product was produced in accordance with CAN/CGSB-32.310, the Organic Production Systems — General Principles and Management Standards and CAN/CGSB-32.311, Organic Production Systems — Permitted Substances List; or meets the export market’s requirements for imports of products labelled organic.

 

(2) The application shall be in writing and shall include evidence that the product has been produced and handled by an operation certified as organic, in accordance with this Regulation.

 

 (3) The certification body shall issue the certificate if it obtains evidence that the operation in respect of which the application was made produced and handled products in accordance with this Regulation.

 

Rationale: OTA believes these minor revisions will enable CFIA to secure better control information, and will give Canada a more effective system to facilitate negotiation for international recognition and/or equivalency.

= = = = = =

 

 10. A person in import trade who wishes to market a product identified as organic shall obtain an attestation issued by the competent authority of the country of origin, attesting that the product is considered to be organic in that country.

= = = = = =

Amend 10. to read:

 

(1) A person in import trade who wishes to market a product identified as organic shall obtain a certificate issued by an organic certification body attesting that the product was produced in compliance with the most recent editions of CAN/CGSB-32.310, the Organic Production Systems — General Principles and Management Standards and CAN/CGSB-32.311, Organic Production Systems — Permitted Substances List, or was produced in compliance with organic standards of other countries with which Canada has negotiated equivalence recognition.

 

            (2) The Bill of Lading accompanying imported product identified as organic shall contain the following information:

(a)  Country of origin.

And either (b) or (c), as appropriate:

(b)  Identification of the certification body that has certified that the product has been produced in compliance with the Canada Organic Regime;

or

(c)  Certified to have been produced in compliance with the organic standards of [country with which Canada has negotiated a mutual recognition agreement] by [name of certifying body and accreditor of the certifying body].

 

Rationale: OTA believes these suggested changes reflect the intent of CAN/CGSB-32.310, the Organic Production Systems — General Principles and Management Standards, which states:

 

"Section 8.1.2 [b]  By way of derogation to par. 8.1.1, the following apply:

 

If an organic product is not produced in Canada, imported ingredients not meeting this standard that are certified by a certification body recognized by the Canadian competent authority are acceptable. Certification must be based on an organic standard approved by a government authority or by using a set of specifications approved by the Canadian competent authority."

 

Additional rationale: OTA believes these revisions create a level playing field for both domestic and imported products covered by this regulation. Furthermore, OTA believes these revisions will enable CFIA to secure better control information, and will give Canada a more effective system to facilitate negotiation for international recognition and/or equivalency.

= = = = = =

 

 Procedure for Organic Certification and Certificate

 

11. (1) A certification body shall certify an agricultural product as an organic product if it determines, after evaluation, that

 

 (a) in the case of an agricultural product containing more than one agricultural product, at least 70% of those products are organic products;

 

 (b) the substances used in its production of the agricultural product are those set out and used in the manner described, in the most recent edition of CAN/CGSB-32.311, Organic Production Systems — Permitted Substances List; and

 

 (c) the methods of production used and the control mechanisms in place comply with the requirements set out in the most recent edition of CAN/CGSB-32.310, Organic Production Systems — General Principles and Management Standards and with the general principles respecting organic production provided for in those standards.

= = = = = =

Move 11.1 (a) to “Labelling 15.” and amend 11.1 with the addition of:

11. 1 (c) the operation is in compliance with the most recent edition of Annex 4 of the Organic Quality Management System Manual.

 

Rationale: OTA FINDS THE ORIGINAL 11.1. (a), “in the case of an agricultural product containing more than one agricultural product, at least 70% of those products are organic products;” is incorrect and is a labeling issue, so should be moved to “Labeling” section, with amended wording. Furthermore, since this section is included in the Organic Quality System Management Manual, it remains under the control of CFIA.

= = = = = =

 

(2) The organic certification remains in effect for a period of one year from the day on which it is granted.

 

 Required Importation Documents

 

12. Every imported product identified as organic shall be accompanied at the time of importation into Canada by the attestation required under section 10.

= = = = = =

Move 12. to Section 10., “International Marketing” and amend to read:

(2) The Bill of Lading accompanying imported product identified as organic shall contain the following information:

(a)  Country of origin.

And either (b) or (c), as appropriate:

(b)  Identification of the certification body that has certified that the product has been produced in compliance with the Canada Organic Regime;

or

(c)  Certified to have been produced in compliance with the organic standards of [country with which Canada has negotiated a mutual recognition agreement] by [name of certifying body and accreditor of the certifying body].

Rationale: OTA proposes this amendment in order to ensure adequate control and simplify the system so as not to impede trade. We reiterate that the end product is not the object of organic certification; certification is based on the methods used in an agricultural, processing or handling operation.

 

NOTE: Numbering of sections will need to be adjusted.

= = = = = =

 

 Suspension and Cancellation

 

13. (1) Subject to subsection (2), the certification body or the Agency shall suspend the organic certification under section 11 if

 

 (a) the holder of the organic certification has not complied with any provision of the Act or these Regulations;

 

 (b) in the case of an agricultural product containing more than one agricultural product, less than 70% of the agricultural products are organic products;

 

 (c) the substances used by the holder in the production of the agricultural product are not those set out, and used in the manner described, in the most recent edition of CAN/ CGSB-32.311, Organic Production Systems — Permitted Substances List; and

 

 (d) the methods used by the holder in the production of the agricultural product do not comply with the requirements set out in the most recent edition of CAN/CGSB-32.310, Organic Production Systems — General Principles and Management Standards and with the general principles respecting organic production provided for in those standards.

= = = = = =

Amend 13. by moving Section 13.1 (b) to “Labelling 15”.

 

Rationale: OTA believes the original 13. (b) “in the case of an agricultural product containing more than one agricultural product, less than 70% of the agricultural products are organic products;” is a labelling issue, and should be moved to “Labelling” and amended.

= = = = = =

 

 (2) No organic certification may be suspended unless the certification body or the Agency, as the case may be, has

 

 (a) notified the holder that there are grounds for suspension;

 

 (b) provided the holder with a copy of a report that specifies the grounds for suspension, the required corrective measures and the period within which those measures must be implemented to avoid suspension; and

 

 (c) sent a notice of suspension to the holder and, in the case of the certification body, sent a copy of it to the Agency.

 

 (3) A suspension of the organic certification remains in effect until the required corrective measures are implemented and verified.

 

 (4) The certification body or the Agency shall cancel the certification if

 

 (a) the holder has not implemented the required corrective measures within the specified period or within a longer period allowed under subsection (5); or

 

 (b) the application made under section 8 contains false or misleading information.

 

 (5) If the holder has not implemented the required corrective measures or their implementation is not possible within the specified period, the certification body may obtain from the Agency a longer period to implement those measures.

 

 (6) No certification may be cancelled unless the certification body or the Agency, as the case may be, has

 

 (a) advised the holder of an opportunity for them to be heard in respect of the cancellation, and the holder was given that opportunity either orally or in writing; and

 

 (b) sent a notice of the cancellation to the holder and, in the case of the certification body, sent a copy of it to the Agency.

 

 PART 4

 

 LABELLING

 

 General Requirements

 

14. In addition to the requirements under this Part, every organic product shall meet the labelling requirements of the Food and Drugs Act and the Consumer Packaging and Labelling Act and their regulations.

= = = = = =

Amend 14. to read:

14. (1) In addition to the requirements under this Part, every product identified as organic shall meet the labelling requirements of the Food and Drugs Act and the Consumer Packaging and Labelling Act and their regulations; and

 

(2) The requirements of Annex 4 of the most recent edition of the Quality Management System Manual.

 

Rationale: OTA believes this revision makes the rule clear to the operators governed by this Regulation and would provide CFIA fuller protection in any legal dispute about labelling. We also suggest that the Quality Management System Manual be referenced wherever appropriate, to ensure that the requirements it details are consistently applied.

= = = = = =

 

 Specific Requirements

 

15. The label of an organic product shall contain:

 

 (a) the name and the accreditation number of the certification body that has certified as an organic product; and

 

 (b) in the case of an agricultural product containing more than one agricultural product, the percentage of each of them that are organic products.

= = = = = =

Amend 15. to read:

15.1. The label of an agricultural product making an organic claim shall contain the name of the certification body that has certified as organic the operation that produced the product; and

 

15.2. The label of an agricultural product making an organic claim may state the following, as applicable:

 

 (a) agricultural product containing 95 percent or more organic ingredients  may be labeled as “Organic ___________”.

 

(b) agricultural product containing 70 percent or more organic ingredients  may be labeled as “Made with Organic ________”.

 

Rationale: This addresses the categories allowed under CAN/CGSB-32.310, the Organic Production Systems — General Principles and Management Standards

NOTE: This section 15.2 replaces the sections moved from 11.1 (a) & 13.1 (b)

= = = = = =

 

 COMING INTO FORCE

 

 16. These Regulations come into force on the day on which they are registered.

= = = = = =

Amend 16. to read:

16. These Regulations come into force on the day on which they are registered. The regulations will be fully implemented 24 to 36 months following registration, to allow the industry to come into compliance at any time during that period. Thereafter, all organic product introduced into commerce in Canada must comply with the Canadian Organic  Regulations.

= = = = = =

 

 Schedule

 (Sections 2 and 3)

 

The logo may be either in black and white, as illustrated, or in colour: on a white background, the outer border in green (Pantone no. 368), the inner border in red (Pantone no. 186) the maple leaf in red (Pantone no. 186), and the lettering in white on a green background (Pantone no. 368).

 

 [35-1-o]

 

 Footnote a

 

S.C. 2001, c. 4, s. 64

 

 Footnote b

 

R.S., c. 20 (4th Supp.)

 

 

 

 

 
 
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