Requirements for certification of organic products at retail level under the Canada Organic Regime
Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.
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- 1) Organic product bears the Canada Organic Logo
- 2) Organic product is marketed inter-provincially or internationally and does not bear the Canada Organic Logo
- 3) Organic product is marketed intra-provincially and does not bear the Canada Organic Logo
Date: September 10, 2019
To: Conformity verification bodies designated by the Canadian Food Inspection Agency (CFIA) and certification bodies accredited by the CFIA
The application of the Safe Food for Canadians Regulations (SFCR) to organic products that are further prepared and/or packaged at retail and labelled as organic at the retail level is dependent on whether the product bears the Canada Organic Logo or whether the product is marketed inter-provincially or internationally.
- par baked bread baked and packaged at retail store
- coffee roasted and packaged at a retail store
- bulk organic nuts packaged and labelled at a retail store
- cookies baked from cookie mix at a retail store
1) Organic product bears the Canada Organic Logo
An organic product that is further prepared at retail, and bears the organic logo, must be certified in accordance with section 345 of the SFCR.
If an organic product is re-packaged or labelled at retail, and bears the organic logo, then the organic product is subject to the SFCR. The retailer must have product certification in accordance with section 345 of the SFCR.
The certification body must certify the organic product after verifying the organic contents and composition, the substances used, the production and processing methods and control mechanisms for purposes of compliance with CAN/CGSB 32.310, CAN/CGSB 32.311 and its general organic production principles (section 345 of the SFCR).
2) Organic product is marketed inter-provincially or internationally and does not bear the Canada Organic Logo
Part 13 of the SFCR applies to all organic products marketed inter-provincially or internationally, therefore must adhere to the same requirements as outlined above in scenario 1.
3) Organic product is marketed intra-provincially and does not bear the Canada Organic Logo
An organic product (not bearing the organic logo) that is further prepared at retail and solely marketed intra-provincially is not subject to Part 13 of the SFCR.
For instance, cookies baked at retail facility from a bulk organic cookie mix (from an out of province supplier) are not subject to Part 13 of the SFCR. As long as cookies do not cross a provincial border, do not identify a certifier and do not carry the Canada Organic logo, the retailer can make an "organic" claim (if there are no prevailing provincial organic regulations otherwise). The retailer is not required to seek certification but must at all times be able to provide records to the CFIA which will show that the organic integrity of the cookies have been maintained, including as this may pertain to any other ingredients used in making the cookie (for example: oil), the storage and handling of either the dry mix or the end-product, record keeping, et cetera.
Note that such products are subject to the Food and Drugs Act (FDA) and Safe Foods for Canadians Act (SFCA) which prohibit false and misleading claims on labels and advertising, as well as any provincial requirements including organic requirements.
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