Chapter 3 - Specific Registration Information by Feed Type
3.24 Organic Label Claims

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The Canada Organic Regime is a regulated system for organic agricultural products, set up by the Government of Canada in response to requests by the organic sector and consumers. Under the regime, the Organic Products Regulations, 2009 (OPR) define specific requirements for organic products that are labelled as organic, or that bear the approved organic agricultural product legend (logo), and are sold interprovincially or are imported. The regulations came into effect on June 30, 2009.

The Canadian Food Inspection Agency (CFIA) is responsible for the monitoring and enforcement of the OPR. Under the Canada Organic Regime, Certification Bodies will be accredited based on the recommendation of CFIA-designated Conformity Verification Bodies. The Certification Bodies are responsible for verifying the application of the Canadian Organic Standards (the Canadian General Standards Board's (CGSB) Organic Production Systems – General Principles and Management Standards (CAN/CGSB 32.310)).

Beginning June 30, 2009, products for which an organic claim is made must be certified by an accredited Certification Body. The Certification Body must certify the product to the Canadian Organic Standards. The CFIA is working with designated Conformity Verification Bodies to accredit Certification Bodies under the Canada Organic Regime. Inquiries regarding the OPR should be directed to the Canada Organic Office.

Livestock feeds are regulated under the Feeds Act and Regulations and the Health of Animals Act and Regulations, which are administered by the CFIA. Under the Feeds Regulations, any product with a claim must be assessed and evaluated. Prior to the implementation of the OPR, feeds with an organic claim required registration to ensure that the product was properly certified in accordance with the voluntary Canadian Organic Standards.

The OPR now provide clear regulatory authority on the certification and assessment of products making organic claims. The Animal Feed Division of the CFIA is working in conjunction with the Canada Organic Office to ensure a smooth transition to the implementation of the new OPR, and to avoid duplication of assessment.

It is important to note that organic feeds will always need to meet the requirements of the Feeds Act and Regulations. As with other feeds, organic feeds may be exempt from registration, if they meet all regulatory requirements and meet the criteria for exemption from registration.

There are three categories (types) of organic claims which are permitted under the OPR for products in interprovincial and international trade.

Category I claims are for single ingredient products, or multi-ingredient products that are comprised of at least 95% organic ingredients. These products may make the claim as part of the product name (e.g. "Organic Corn" or "Organic Chicken Feed") and may use the approved logo.

Category II claims are for multi-ingredient products in which 70 to 95% of the ingredients are organic. These products may indicate the % organic ingredients.

Category I and II claims on feed labels will not require feed registration if OPR requirements are met, provided that they meet all of the Feeds Regulations registration exemption criteria.

Category III claims for multi-ingredient products that contain less than 70% organic ingredients. These products may indicate organic ingredients in their list of ingredients. This type of claim on a feed will require registration by the Animal Feed Division of the CFIA, as it is not assessed by a certification body under the OPR.

Organic feeds may only contain ingredients which are approved per Schedules IV and V of the Feeds Regulations, and are on the Permitted Substances List (CGSB's Organic Production Systems Permitted Substances Lists (CAN/CGSB 32.311)). The Permitted Substances List includes both ingredients which may be certified as organic (e.g. grains), and additives and supplements (sometimes called "inputs") such as vitamin and mineral sources, which cannot be certified as organic. Ingredients on the Permitted Substances List must be used in accordance with the origin and usage restrictions that are listed.

Ingredients from the Permitted Substances List which are not certifiable as organic (e.g. minerals) may not make any label claims indicating that they are organic. They also cannot contain claims such as "approved for use in organic agriculture", or "certified approved for use in organic agriculture". These are not claims that are permitted under the OPR. There is currently no program in place for certification bodies to certify a product comprised of non-certifiable ingredients from the Permitted Substances List as approved for use in organic agriculture. Feeds also cannot claim to be listed or approved by the "Organic Materials Review Institute (OMRI)", nor can they claim to be included on any other international Permitted Substances List, as other countries have organic standards and permitted substance lists that are different from Canada's.

The feed regulatory requirements, including labelling, and restrictions pertaining to organic claims are outlined below:

Domestic Organic Feeds (Interprovincial Trade)

Category I Claims: Organic

Feeds that are certified organic (i.e. more than 95% organic ingredients) in accordance with the OPR will not require registration of the organic claim by the Animal Feed Division of the CFIA with the following conditions:

Labels must:

  • have the term "organic" in association with the common name of the product (e.g. XX Mill's Organic Complete Feed for Laying Hens);
  • bear the name of a CFIA-accredited certification body1;
  • bear the words "imported" or "product of [country name]"; for imported products that bear the "Canada Organic" logo;
  • indicate which ingredients in the list of ingredients (if present) are organic; and
  • meet the requirements of the Feeds Regulations.

Labels may:

  • use the "Canada Organic" logo;
  • use terms such as organic; organically grown; organically raised; organically produced, or words of similar intent, including diminutives of, symbols for, and phonetic renderings of these words (e.g., "organik");
  • use the logo of the certification body; and/or
  • require registration, if the product does not meet all of the Feeds Regulations registration exemption criteria.

Labels can not:

  • × have label statements such as "certified organic" or "100% organic"; nor
  • × have statements such as "made with organic x" or "includes organic x".

Category II Claims: 70-95% Organic

In the case of a multi-ingredient product whose contents are more than 70% and less than 95% organic, the % organic may be claimed provided the certifying body has approved this claim. This claim does not require feed registration, with the conditions that:

Labels must:

  • bear the statement "% organic ingredients", immediately following the percentage number rounded down to the nearest whole number;
  • bear the name of a CFIA-accredited certification body1;
  • indicate which ingredients in the list of ingredients (if present) are organic; and
  • meet the requirements of the Feeds Regulations.

Labels may:

  • use the logo for the certification body; and/or
  • require registration, if the product does not meet all Feeds Regulations registration exemption criteria.

Labels can not:

  • × use the "Canada Organic" logo;
  • × have statements such as "certified organic";
  • × have the term "organic" as a descriptor of the common name of the product; nor
  • × have statements such as "made with organic x" or "includes organic x".

Category III Claims: Contains Organic Ingredients

Multi-ingredient products which contain less than 70% organic ingredients may indicate the organic ingredients within the list of ingredients. As these claims are not assessed by a certification body, feeds that indicate which ingredients are organic in the list of ingredients must be registered by the Animal Feed Division.

Companies will need to submit the standard feed registration information, as outlined in Chapter 1 of this document, as well as copies of the organic certification for the organic ingredients used in the feed. All organic ingredients must be certified organic in accordance with the OPR. Companies must also submit information such as policies and procedures which detail how adulteration or cross-contamination with non-organic material is prevented.

Labels must:

  • be as they are approved by the Animal Feed Division; and
  • have a valid feed registration number.

Labels may:

  • indicate the organic ingredient(s) in the list of ingredients.

Labels can not:

  • × use the term "organic" anywhere other than the list of ingredients;
  • × use the "Canada Organic" logo;
  • × indicate the % organic ingredients;
  • × indicate the name of a certification body; nor
  • × have statements such as "made with organic x" or "includes organic x".

Please note that organic feeds may still require registration with the Animal Feed Division if they do not meet all exemption from registration criteria as outlined in the Feeds Act and Feeds Regulations.

Domestic Organic Feeds (Intra-Provincial)

Products that are manufactured and sold within a single province (i.e. intra-provincial) are exempt from the OPR. An organic claim on a feed that is manufactured and sold within a province, and that is not in accordance with the OPR, is required to be registered in support of the product being certified, in accordance with the Canadian General Standards Board organic standard or an equivalent standard.

Imported Organic Feeds

All mixed feeds, and feed ingredients listed in Schedules IV or V, Part II, require registration before they are imported into Canada. Feed ingredients listed in Schedules IV or V, Part I, are exempt from registration, provided that they meet the regulatory standards, including the approved definition, and are properly labelled. Imported feeds may make an organic claim subject to the following conditions:

Labels must:

  • meet the criteria for the appropriate claim category (I, II or III) as listed above;
  • declare the country of origin ("imported"or "product of X") in close proximity to the "Canada Organic" logo, if used (Category I only); and
  • be certified by a certification body that is accredited by a Competent Authority or certification body that is accredited by the CFIA.

Labels may:

  • bear the "Canada Organic" logo if the product has a Category I organic claim; and/or
  • require feed registration.

Enforcement of Organic Regulations

CFIA inspection staff will verify organic claims during routine inspections. Regulated parties are reminded that the Feeds Act and Regulations continue to apply, and that enforcement action may be taken under the Feeds Act and Regulations if non-compliant product is found in the marketplace.

All feeds (including organic feeds) that are manufactured, sold, or imported into Canada may only use approved ingredients per Schedules IV and V of the Feeds Regulations. The presence of other (unapproved) ingredients is considered non-compliance requiring corrective and/or enforcement action.

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