Canada Organic Regime operating manual
Appendix C - The family of certification documents

Documentation requirements for verification of continued organic integrity under the Canada Organic Regime

(Interpretation of Part 13 of the SFCR)

The "family" of certification documents

Because an organic product carries its certification until the next point of transformation, operators may require different types of document to attest to a product's organic status and integrity. These documents are:

  1. organic product certificate
  2. certificate for labelling and/or packaging activities
  3. attestation of compliance for a service provider conducting activities, excluding packaging and labelling activities

These documents are considered the "family" of documents, which can be issued by a CFIA-accredited certification body (CB) in order to attest to the organic integrity of a product. For products and ingredients imported to Canada, parties within the Canada Organic Regime (COR) shall recognize organic certificates from equivalent organic systems.

The COR operating manual requires that all CFIA-accredited CBs accept certification documents including attestation of compliance, issued by another CFIA-accredited CB or any CB recognized under equivalency arrangements as meeting the SFCR requirements for the maintenance of organic integrity.

Whenever a document is issued, there must be verification that the operator requesting certification complies with the Canadian Organic Standards, such as requirements related to the organic plan.

Types of documentation issued by the CBs to verify continued organic integrity under COR
Type of Documentation Description
Organic Product Certificate CBs shall issue certificates confirming the organic status of a product, verified to be produced or processed in compliance with the Canadian Organic Standards as per section 345(2) of the SFCR. Product certificates do not expire; however, section 346(1) of the SFCR requires the certification holder to submit updated information annually.
Certificate of packaging and labelling activities CBs shall issue certificate of packaging or labelling activities to an operator as per clause 348(2) of the SFCR.
Attestation of compliance document CBs may issue an attestation of compliance confirming that the service provider conducted an activity on behalf of an organic operator in compliance with the Canadian organic standards as per clause 344(2)(c) of the SFCR. The CB shall issue the attestation of compliance in accordance with C.11 of the COR operating manual.
Expiry/renewal of documentation
Type of document Expiry/Renewal
Organic Product Certificate Does not expire.
A certificate must be issued for an organic product on an annual basis as per 345(2) of the SFCR.
Organic Packaging and Labelling Certificate Remains in effect for a period of 12 months beginning on the day on which it is granted as per section 348 (3) of the SFCR.
Attestation of Compliance Remains in effect for a period of 12 months beginning on the day it was granted as per C.11 of the COR operating manual.
Example scenarios
# Operator Scenario Type of Document
1 Farmer (primary producer) The primary producer sells an organic product to a retailer or manufacturer without any processing or transformation. Organic Product Certificate
Any transport or handling of the product included in the organic plan by the farmer is covered by this certificate.
Subsequent activities such as processing, transformation, packaging, and labelling by other parties are not covered by the organic product certificate issued to the primary producer.
2 Trader - Domestic Distributor The trader sells an organic product to a retailer such as bulk products obtained from a farmer or manufacturer. The product has not been transformed but the trader wishes to show that the organic integrity of the product has been maintained. Organic product certificate
The trader may apply for product certification and sell the organic product under this documentation (e.g. as the organic integrity has been verified, the name and address of the supplier are not required to be disclosed to the buyer).
However, traders or distributors can still trade organic products without applying for organic product certificate, provided that organic integrity has not been compromised and the full documentation chain for these products is on hand and provided as required by either the certification body or the CFIA inspectors.
3 Trader - Exporter – Equivalency Arrangement - Certificate of Inspection required The exporter sells an organic product to an export market with whom Canada has an equivalency arrangement and the competent authority of the export market requires a "Certificate of Inspection" as is the case with the European Union, Switzerland and Japan. Organic product certificate and Certificate of Inspection
The certificate of inspection should be issued by the CB that certified the product as organic.
4 Trader - Exporter – Equivalency Arrangement – Certificate of Inspection not required The exporter sells an organic product to an export market with whom Canada has an Equivalency Arrangement but no Certificate of Inspection is required (e.g. United States and Costa Rica) Organic product certificate
Canadian organic products exported to the U.S. under the USCOEA must be accompanied by a valid organic product certificate issued by a Canadian Food Inspection Agency (CFIA) accredited certification body, which includes the following attestation statement, "Certified in compliance with the terms of the U.S.-Canada Organic Equivalency Arrangement".
5 Trader - Exporter – No Equivalency Arrangement The exporter sells an organic product to an export market with whom Canada does not have an Equivalency Arrangement Organic product certificate should be issued if the product is marketed in Canada.
Import requirements of the country where the product will be marketed must be met.
6 Re-packager/Re-labeller (processor) An operator purchases an organic product but changes its container (for example, from bulk to single-package), changes its packaging, or provides a new label (i.e. changing or adding information to the original package). Organic product certificate
7 Retailer (sale of bulk product from bins) A retailer purchases bulk product for sale in its store and back-fills the bins as levels get lower. These bins are labelled "organic" and carry the Canada Organic Logo. Organic product certificate
Retailers, who choose to blend, further prepare, package or label organic products and use the Canada Organic Logo are required to obtain certification under the federal system.
8 Retailer (repackaging of bulk product into small packages) A retailer purchases bulk product for sale in its store and re-packages i.e., makes individual-sale units available. These packages are labelled "organic" and carry the Canada Organic Logo. Organic product certificate
Retailers, who choose to blend, further prepare, package or label organic products but choose not to use the Canada Organic Logo, and do not cross provincial lines, are not required to obtain certification under the federal system. The Canada Organic Retailing Practices Guide is recommended for best management practices in such situations. However, in certain provinces, the retailer may have to obtain certification under a provincial regime
9 Brand owner (products under a private label) A brand owner buys (under contract) prepackaged products via third-party producers or manufacturers and markets them under their own brand of product. Organic product certificate
The brand owner may apply for product certification and sell the product under this documentation. It is not necessary to disclose the name and address of the original supplier on the packaging as long as the brand owner’s name and address is included. The label must display the name of the CB which issued the final organic product certificate. The certification is not mandatory if the name and address of the original supplier is disclosed on the final packaging.
10 Manufacturer/ processor A manufacturer/ processor buys organic product from a trader or producer and transforms it into a new product. Organic Product Certificate
All organic ingredients must be accompanied by their organic product certificate, and the manufactured/processed products must be issued organic product certificates by a CB under the COR.
11 Contract packaging and labelling activitiesContract service providers that only package and label organic products on behalf of the organic product certificate holder Certificate for packaging or labelling activities
12 Contract services excluding packaging and labelling and final product preparation i.e., services conducted on behalf of the organic product certificate holder. Contract service providers (e.g. for slaughter, transport, storage, seed cleaning, etc. excluding packaging and labelling) who perform contractual work for operators in relation to certified organic products but the ownership of the product continuously rests with the holder of the organic certificate. Attestation of Compliance
  1. To be issued in accordance with section C.11 of the COR Operating Manual,
    or
  2. the service provider must be included in the on-site verification of the CB for the product certification.
13 On-site services or equipment (e.g. mobile juicers) A certified operation (e.g. a farm) leases or loans equipment or has services that are performed on-site, but the ownership of the organic product continuously rests with the organic product certificate holder.None
If the organic plan includes this situation, and the CB is able to verify compliance to the standards, including cleaning requirements, then the equipment or service may be covered by the original organic product certificate.
or
Attestation of Compliance
May be issued in accordance with section C.11 of the COR Operating Manual.
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