Canada Organic Regime Operating Manual
Part C Certification of Organic Product and CB Requirements

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C.1 Objective

This section provides information about the certification cycle, including application for certification, evaluation, decision on certificationand continuation of thecertification under the Canada Organic Regime (COR). It also provides requirements on the CB. The CVB shall verify that the CB meets these requirements during every initial, surveillance or reassessment audit conducted by the CVB.

C.2 Procedures for Certification Under COR

C.2.1 Application for Initial Certification of Agricultural Product

  • C.2.1.1 The CFIA accredited CB shall ensure that operators seeking certification of their organic product or process shall make an application as defined by the CB.
  • C.2.1.2 The CB shall require that the applicant provide all the relevant documents and information deemed essential to the assessment as described in Section 12 (2) from the Regulations and section C.7. These documents shall include, as a minimum:
    • C.2.1.2.1 production description, production and/or preparation specifications for products to which the application applies;
    • C.2.1.2.2 maps and plans;
    • C.2.1.2.3 list of inputs (ingredients and agricultural substances);
    • C.2.1.2.4 a copy of organic production and/or preparation plans;
    • C.2.1.2.5 names of Certification Bodies to which prior applications for certification were submitted by the applicant within the previous years, including all details pertaining to processing the application, and the resulting decision.
  • C.2.1.3 The CB shall send acknowledgement of the application reception to the applicant before continuing with the application review.
  • C.2.1.4 The CB shall ensure that the applicant pays the fees for certification according to the CB's contract for services and in accordance with the CB's fee schedule.
  • C.2.1.5 The CB shall verify that the applicant does not hold more than one product certification to the Canadian Organic standard for any given operation site under the Canada Organic Regime.
  • C.2.1.6 The CB shall verifythe accuracy of submitted documentation and its conformance to the requirements of the organic standard.

C.2.2 Preparation for on-Site Inspection

  • C.2.2.1 The CB shall document its procedure for its evaluation activities. The CB shall evaluate the products of the applicant against the requirements set out in CAN/CGSB-32.310 and CAN/CGSB-32.311.
  • C.2.2.2 The CB shall not permit the operators to choose or to recommend the VO except in cases of conflict of interest.
  • C.2.2.3 The CB shall record the VO selected to evaluate the conformance of the operator's product or process.
  • C.2.2.4 The CB shall ensure that the operator is contacted to arrange the logistics of the on-site inspection.

C.2.3 on-Site Inspection

  • C.2.3.1 The CB shall ensure that the inspection covers the entire agricultural production system being managed by the operator, even if only part of the operator's operations were targeted by the certification application.The inspection of an operation site shall cover all production and processing operations, including packaging and labelling pertaining to the product.
  • C.2.3.2 The CB shall ensure that systems and facilities upon which an operator relies to produce and/or prepare each product included within its application is to be visited by the assigned VO to ensure that the standards are fully applied and correspond to the submitted production or preparation specifications.
  • C.2.3.3 The CB shall ensure that the assigned VO conducts an introductory meeting with a representative of the operator.
  • C.2.3.4 The CB shall ensure that the land, premises and equipment not included in thecertification application are identified and checked, andshall at a minimum include the following: crop areas orharvesting zones; harvest storage locations; preparation,processing and packaging sites; application dates forphytosanitary products.
  • C.2.3.5 The CB shall verify that prohibited substances have not been, andare not being, applied to the operation.
  • C.2.3.6 The CB shall ensure that the VO conducts a review of record keeping, to verify that the organic plan previously submitted to the CB accurately reflects the operation and is in compliance with the Canadian Organic Standard. Records to be verified include records related to production (ex: inventory, sales, purchases) and to management (e.g., accounting, complaints); as well as appropriate product packaging and labelling.
  • C.2.3.7 The CB shall ensure that the VO conducts a visual examination of each production unit (e.g. fields, crops, plants, livestock, buildings, facilities and vehicles) where production or preparation of agricultural and food products are carried out.
  • C.2.3.8 The CB shall ensure that the VO witnesses the way the operator proceeds at a given point within the production cycle, thus implying that the inspection shall be carried out when grounds, premises, and activities subjected to compliance requirements may be observed.
  • C.2.3.9 The CB shall ensure that the inspection includes non-organic units where there is reason to suspect undeclared split production of similar products, and in any situation revealing high risk of cross-contamination; where agricultural producers carry out split production, inspections shall allow visual determination of what is being planted in all cultivated fields within the production unit.
  • C.2.3.10 The CB shall ensure that the VO identifies and investigates areas of risk (e.g. potential contamination from neighbouring farm, flooding).
  • C.2.3.11 The CB shall ensure that for producers, the VO obtains an estimate of the potential yield for the coming year, as well as an audit of the balance in the quantities produced and sold over the previous period, and including amounts still in inventory during this same period.
  • C.2.3.12 The CB shall ensure that for applicants performing operations related to food preparation (processing and/or packaging), the VO calculates the input/output balance for acquired commodities for a product, and for the corresponding inputs included in the products sold and on inventory.The calculation sample shall include the most prominent commodities for at least 10% of all commodities used in all products with a minimum of one and maximum of 5. However, if justified by the VO, a different or additional commodity may be included in this calculation. This justification shall be recorded in the inspection report.
  • C.2.3.13 The CB shall ensure that the VO performs traceback audits applying to certain products taken from the supplier's inventory or from a commercial outlet where its products have been placed for sale.
  • C.2.3.14 The CB shall ensure that the VO verifies that changes in the standards and requirements of the CBhave been effectively implemented by the operator.
  • C.2.3.15 The CB shall ensure that the VO verifies that previously imposed conditions have been fulfilled;
  • C.2.3.16 The CB shall require pre-harvest or post-harvest testing of any agricultural input used or agricultural product to be sold, labelled or represented as being in compliance with the requirements of the Canadian Organic standards when there is a reason to suspect that the agricultural input or product has come into contact with a prohibited substance, method or ingredient in the production and handling of organic products.
  • C.2.3.17 The CB shall ensure that when samples are taken by the VO, the VO shall provide the operator with a receipt for each sample.
  • C.2.3.18 The CB shall require sampling and testing, in an event of a complaint concerning the use of or contamination with prohibited substance, as part of the investigation of the complaint.
  • C.2.3.19 The CB shall investigate if it has a suspicion that an organic product contains even a trace amount of a GMO. The CB shall require sampling and testing in an event of suspicion of the presence of GMO.
  • C.2.3.20 The CB shall ensure that the VO interviews people knowledgeable with the operation at present.
  • C.2.3.21 The CB shall ensure that the VO:
    • C.2.3.21.1 conducts a closing meeting at the end of the visit, intended to inform the operator's management of inspection results as well as findings made concerning the compliance with certification requirements, without any corrective action request from the VO.
    • C.2.3.21.2 provides opportunity for the operator to confirm the accuracy of information collected during the inspection;
    • C.2.3.21.3 provides a summary of this review to the operator;
    • C.2.3.21.4 addresses the need for any additional information as well as any issues of concern.
  • C.2.3.22 The VO shall submit to the CB a report mentioning verification results and findings as to the conformity with all certification requirements, and including the following data as a minimum:
    • C.2.3.22.1 date, time and duration of inspection;
    • C.2.3.22.2 names of interviewees;
    • C.2.3.22.3 identification of land and premises visited on the production/handling site;
    • C.2.3.22.4 types of documentation audits performed (in/out balance sheet, yields/sales, audit trails by batches, etc).

C.2.4 Timing of on-Site Inspections

  • C.2.4.1 In cases involving producer operations, the timing of on-site inspection shall take place during the production season. This period begins as soon as all operations subject to inspection (seeding, tapping, etc.) begin and ends with the packaging or placing in containers for storage of products to be certified.
  • C.2.4.2 In cases involving processing operations, on-site inspections may be carried out any time during the year. on the other hand, for separated production (i.e., when both certifiable and non-certifiable products are manufactured at the same facility), the inspection shall be carried out at time when the products that are targeted for certification are being processed.If the CBdetermines it is not possible to conduct the inspection while organic product is being processed, the CB shall record the reason(s) supporting this determination. The CB shall then arrange for the inspection to be conducted at a time when the facilities and activities that demonstrate compliance or capacity to comply can be assessed. There shall be no more than two consecutive years without an inspection when organic product is being processed.

C.2.5 Evaluation Report

  • C.2.5.1 The CB shall require from the operator to respond to the non conformity report issued by the Certification body within 30 days of its receipt. The response shall either provide evidence of completion of corrective action taken to address each NC or present a plan with milestones as to how each NC will be addressed. This plan shall include a completion date not exceeding 90 days from receipt of the NCs. The CB shall accept times greater than those stated for the closure of a nonconformance as long as they are justified and documented.

C.2.6 Nonconformity Follow-Up

  • C.2.6.1 The CB shall ensure that corrective actions aiming to address all nonconformities have been implemented by the operator by conducting on-site visit or other appropriate forms of verification.
  • C.2.6.2 The CB shall inform the applicant that at any point within the certification cycle, preceding the CB's decision, the applicant may request that the processing of its application be stopped. The applicant shall be informed that they are liable for the costs of services provided up to the time of withdrawal of its application. In such case, the CB shall not issue a decision regarding the products that were the subject of the certification request.
  • C.2.6.3 If a CB has reason to believe that an applicant for initial certification has wilfully made a false statement regarding its production system and operations related to the products included in the application, the CB may deny certification, without issuing a notification of non-compliance.
  • C.2.6.4 The CB shall issue a written notice of denial of certification to any applicant to whom it denies certification, either because operations resulting in the products included in the application are still noncompliant with requirements or simply because the applicant did not respond to the notification of non-compliance. This notice shall state the reason(s) for denial and the applicant's right to:
    • C.2.6.4.1 file an appeal of the denial;
    • C.2.6.4.2 reapply for certification to any accredited CB, including the one who denied certification.

C.2.7 Certification Decision

  • C.2.7.1 The decision to certify a product shall be taken if the CB determines that all procedures and activities contained in the organic plan are in compliance with OPR requirements and that the applicant is able to conduct operations in accordance with this plan and after the correctionof all nonconformities. This decision is valid until the results of the next annual evaluation are known and a new decision is madeor unless the CB is made aware of information to cause the CB to act (e.g. suspension or withdrawal). This information can come from an external source or from the CB's own efforts.
  • C.2.7.2 The CB shall issue documents to the applicant confirming the organic certification of the product. These documents shall include the following:
    • C.2.7.2.1 the scope of the certification granted, including, as appropriate:
    • C.2.7.2.1.1 the products certified, which shall be identified by type or range of products including their specific name and if applicable, the one or more trademarks under which they are being marketed;
    • C.2.7.2.1.2 the product standards or other normative documents concerning, under which each product or product type is certified;
    • C.2.7.2.1.3 the applicable certification system (as defined by ISO Guide 67) with the type(s) of operations and subject of the evaluation by the CB, among the following:
      • crop production;
      • livestock production;
      • grain production;
      • maple syrup production;
      • specialized production ( bee-keeping, etc);
      • food processing;
      • subsequent packaging (labelling modification following an operation of breaking down or regrouping on products already certified);
      • brokerage
    • C.2.7.2.2 the date on which the certification was granted;
    • C.2.7.2.3 the date by which the operator shall submit application for subsequent annual inspection;
    • C.2.7.2.4 the location of all operations covered by this certification (town, province/state, country);
    • C.2.7.2.5 in the case of product packaging and labelling certification, the date on which the certification document expires.
  • C.2.7.3 The certification of a product, once issued, shall remain valid unless suspended or cancelled by the CB according to the requirements of the OPR.
  • C.2.7.4 The CB shall follow the OPR requirements for cancellation under clause 20 (6) in case of voluntary withdrawal by the operator.

C.2.8 Procedure for Continuation of Certification

  • C.2.8.1 The CB shall document the procedures to verify annually that the criteria for certification continue to be met by the operator.
  • C.2.8.2 The CB shall require that the operator apply annually for continued organic certification.
  • C.2.8.3 The CB shall proceed when the operator submits all information requested by the CB and pays annual certification fees.
  • C.2.8.4 The CB shall initiate suspension or cancellation in cases where the application is not submitted within the time prescribed in the OPR (section 12 (1)).
  • C.2.8.5 The CB shall evaluate applications for continued certification to verify that all the requirements for certification are met resulting either in continuation of the certification or initiation of suspension and cancellation.
  • C.2.8.6 The CB evaluation for continued certification shall include asa minimum:
    • C.2.8.6.1 Anon-site inspection to each location where each operator is operating, to verify compliance with the applicable requirements as outlined in C 2.3.
    • C.2.8.6.2 If an inspection visit shall occur on a date beyond a period of twelve months following the inspection from the previous year, this postponement shall not exceed six months, shall be justified and shall be documented.
    • C.2.8.6.3 When the interval between two regular inspections has exceeded twelve months, the CB shall make sure that subsequent inspections restore the parity between the number of calendar years and the number of regular inspections over a given period.
  • C.2.8.7 The CB shall make its certification decision for continued certification as outlined in C.2.7.

C.2.9 Additional Inspections

  • C.2.9.1 In addition to the annual inspections the CB shall plan and conduct unannounced inspections representing 3% of primary producers (minimum one)and 5% of other operators (minimum one) to which it grants certificates for products under the Canada Organic Regime The CB shall document the procedure covering the frequency and selection criteria for these additional unannounced on-site inspections. In cases where it is not possible to conduct an unannounced inspection (e.g. for reasons related to site access or any other factors supported by a justification), advance notice may be given providing that this notice period does not allow time to cover up non-compliances that might exist. In any case the notice shall be not more than 24 hours. The CB shall document the reasons for any advance notice.
  • C.2.9.2 Unannounced inspections may be limited in scope and may cover only certain aspects of the operation. The operators chosen for unannounced inspections may be random, risk based, or as a result of a complaint or investigation. The CB is not obliged to disclose to the operator the reason for the unannounced or additional inspection.
  • C.2.9.3 The CB shall comply with any requests from the Canada Organic Office or the CVB that additional inspections be conducted by the CB when the compliance of the operation is in doubt or for other valid reasons.

C.2.10 Suspension and Cancellation

  • C.2.10.1 The CB shall suspend an organic certification as per Section 20 from the Regulations as amended from time to time.
  • C.2.10.2 The CB shall report to its CVB all suspensions and cancellations it issues on the 25thof each month, in case such decisions are made, or shall be provided as defined by the CVB. All suspensions and cancellation reports shall include the name of the operator, the date of issue and the reason for the action.
  • C.2.10.3 The CB shall reinstate suspended certification only after the CFIA has been notified and the date of the certification reinstatement is posted on the CFIA published list of suspended and cancelled organic certifications
  • C.2.10.4 The CB shall not grant certification to an operator who had its certification previously cancelled and whose name appears on the CFIA published list of suspended and cancelled organic certifications unless the operator has submitted an application for certification of agricultural product to a CFIA accredited CB as per section C.2, has completed the organic certification process and the CB has received a conformation from the CFIA that the date of the certification reinstatement is posted on the CFIA list.
  • C.2.10.5 The CB shall submit to the CFIA a request for having the date of the certification reinstatement posted on the CFIA list of suspended and cancelled organic certifications within 5 working days from the certification decision
  • C.2.10.6 The CFIA shall post the date of the certification reinstatement on the CFIA list of suspended and cancelled organic certifications and shall send a conformation to the CB within 5 working days from the CB request receipt

C.3 Timing of Sale or Distribution of Certified Product

  • C.3.1 When certification is requested, the CB shall ensure that theoperator does not put up for sale any product "represented as organic" or bearing the word organic or its derivatives until it has been informed by the CB that the products are certified.

C.4 Appeal, Complaint and Dispute Procedures of CB

  • C.4.1 The CB shall document procedures to ensure that it deals with the appeals, complaints and disputes by an applicant or other party pertaining to certification.
  • C.4.2 The CB documented procedures shall deal with, as a minimum:
    • C.4.2.1 appeals related to certification decisions;
    • C.4.2.2 complaints or disputes from operators regarding the CB's program application;
    • C.4.2.3 complaints or disputes from outside persons or organizations about the CB's operation.

C.5 Issues Regarding Implementation of the Standard

  • C.5.1 The CB shall notify all its operators of any amendments to the regulations or the standards within two months after their publication
  • C.5.2 The CB shall allow a period of up to 12 months after the publication date of an amendment to CAN/CGSB-32.310 and CAN/CGSB-32.311 for applicant to come into compliance with any changes to the requirements.
  • C.5.3 If at any point during certification activities, interpretation of an applicable standard is required, it can be sought from the Standards Interpretation Committee (SIC). Refer to Part G for details about this committee and on how to request an interpretation.
  • C.5.4 It is likely that the need for interpretation requests to the SIC will occur during a certification cycle of an operator by a CB. In such cases, where both parties agree there is need for interpretation or clarification andthe interpretation request is submitted by the CB, the issue that is the subject of the request will be set aside by the CB(e.g. the nonconformity will be placed on hold) until the response from the SIC is returned.
  • C.5.5 In these cases, between the time when the interpretation request to the SIC is submitted and the response from the committee returned, any certification work affected by the interpretation shall proceed as normal, up to and including the issuance of certification documents.
  • C.5.6 When the response from the SIC is received, the outstanding issue shall be revisited and appropriate actions taken by the CB or the operator or both as required.
  • C.5.7 If changes are required by the operator to comply with the interpretation of the SIC, the CB shall not suspend or withdrawal any certification it has issued that is affected by this interpretation as long as the operator has made the required changes in a time frame that is no less than the time permitted for any other non-conformance issued by the CB.
  • C.5.8 In cases where the CB and the operator do not agree that the issue needs an interpretation, the CB shall rely on CAN/CGSB-32.310, section II - General Principles of Organic Production and Par. 1.4.1. when interpreting the issue. The operator is still able to make a complaint to the CVB about the CB and/or ask the SIC for an interpretation and request a reconsideration of the issue at a later date.

C.6 Use of Licenses, Certificates and Marks of Conformity

  • C.6.1 The CB shall have a signed license agreement with each operator for products which it has certified.
  • C.6.2 The CB shall ensure that all certified products are labelled in accordance with the OPR.
  • C.6.3 The CB shall withdraw the agreement if the operator:
    • C.6.3.1 ceases doing business with the CB or;
    • C.6.3.2 cannot demonstrate that it is able to comply with the applicable standards for operations included in its certification application.
  • C.6.4 The CB shall have procedures to monitor products using its certification mark and its name and being sold on the market, to detect any improper or fraudulent use of their mark and mandatory labelling (section 25 of the OPR).
  • C.6.5 The CB shall have written rules authorizing the use of its mark (including the recognition of product labels on which it shall be displayed) and is responsible for delivering the organic certificates.
  • C.6.6 The CB shall have written procedures for dealing with abusive use, false statements regarding a product's certification or the incorrect use of its certification marks.
  • C.6.7 The CB shall have procedures ensuring that its operators do not allow its certification mark be used in any way likely to lead to confusion among consumers.

C.7 Obligations of the CB Relative to Certifications

  • C.7.1 The CB shall not issue a certificate for any product unless all the ingredients have been certified as organic in accordance with the OPR or that has been certified as organic under section 27 of the OPR.
  • C.7.2 When a subjective judgment is required to determine compliance, the CB shall document explanatory information, assuring consistent and uniform application of the requirements and certification decisions.
  • C.7.3 The CB shall ensure that when it identifies and assigns responsibilities and tasks to members of its staff, impartiality is not in jeopardy.
  • C.7.4 The CB shall identify the management (committee, group or person) which have overall responsibility for undertaking monitoring, inspection and certification activities as defined within the accreditation criteria, including execution of inspection, controls, evaluation and certification.
  • C.7.5 The CB shall have a signed agreement with each operator that specifies the rights and responsibilities relevant to its certification activities.
  • C.7.6 The CB shall include provisions to cover liabilities in situations where there is a significant risk of being sued.
  • C.7.7 The CB shall document the minimal qualifications required for VO. The CB shall ensure relevant professional training or experience in compliance with the CB's Quality Management System requirements including training with respect to the Canada Organic Regime.
  • C.7.8 The CB shall have a signed agreement with the VO to refuse any work that would create a conflict-of-interest situation with the enterprise that is applying for certification, either because of a family link, or because of a business relationship with the applicant during the twelve months preceding its application to the CB.
  • C.7.9 The CB shall document its rules for inspection.
  • C.7.10 The CB shall record the VO selection for a given inspection.
  • C.7.11 The CB shall record the annual VO performance appraisal.
  • C.7.12 The CB shall document the grounds on which an applicant might refuse the choice of VO and shall inform the operator of these grounds, prior to, or along with, the name of the VO being provided to the operator.
  • C.7.13 The CB shall document frequency and estimated duration of on-site inspection, taking into account the intensity of the production system, the production type, the company's size, the results of the previous verification, complaints received, parallel production.
  • C.7.14 The CB shall document the minimum requirements for any audit trail, in relation to traceability.
  • C.7.15 The CB shall document its sampling and testing requirements.
  • C.7.16 The CB shall document itsdeadlines for presentation of the VO report to the CB.
  • C.7.17 The CB shall have procedures to address cases when an operator does not renew a certification of its product from a previous year to ensure that the CB shall formally notify this operator in a timely manner that its certification is withdrawn.
  • C.7.18 The CB shall exchange information with other CBs and /or CFIA to verify the validity of the information on an operator.

C.8 Records Control by the CB and Operator

  • C.8.1 The CB shall document procedures that ensure it maintains a record system that complies with the OPR requirements.
  • C.8.2 The CB shall ensure that its records are to be kept for a minimum of five years. This requirement shall also be documented by the CB.
  • C.8.3 The CB shall ensure that the operator maintain records and relevant supporting documents concerning the inputs, production, preparation and handling of crops, livestock and organic products that are or are intended to be sold, labelled or otherwise represented as organic in accordance with the CAN/CGSB-32.310.

C.9 CB Records

  • C.9.1 The CB shall record all data listed below and shall provide it to the CVB and COO annually by the end of the calendar year for each operator granted certification. For those elements of this information provided via the Internet, it is acceptable to provide the URL to this information instead. For those elements of this information not provided via the Internet, that information shall still be provided annually by the CB and the CVB shall transfer it to the CFIA.
    • C.9.1.1 Legal (corporate) name of operator.
    • C.9.1.2 Full address of the of operator's head office including phone numbers and fax numbers.
    • C.9.1.3 Type of operation (primary, processing or exporter).
    • C.9.1.4 Generic names of the products certified.
    • C.9.1.5 one example of a package using the certification marking (an electronic copy is acceptable).
  • C.9.2 The CB shall maintain records of all major changes that took place during the previous year and that have affected corporate structure and directors, the administrative structure, the main managers of the organization and members of the committees. It shall provide this information to the CVB or the CFIA upon request.
  • C.9.3 The CB shall maintain records of all modifications made to policies, internal procedures and regulations governing the organization and its certification system. It shall provide this information to the CVB or the CFIA upon request.
  • C.9.4 The CB shall maintain records of the certificates newly issued, renewed, suspended and withdrawn listed by operator category under the COR. It shall provide this information to the CVB or the CFIA upon request.

C.10 Requirements When an Operator Changes a CB under the COR

C.10.1 Requirements on the Operator

  • C.10.1.1 The operator who wishes to change their current CB (sending) to a new CB (receiving) shall complete an application form prescribed by the new CB and follow the application requirements as per C.2.1.
  • C.10.1.2 The operator shall notify their current CB of their intent to change the CB.
  • C.10.1.3 The operator shall maintain their current certification until the new CB has issued documents confirming the organic certification of the operator's products as per Section 13 (2) of OPR.
  • C.10.1.4 The operator shall not use up existing supplies of labels which identify their current CB on products they produce.

C.10.2 Requirements on Sending CB

  • C.10.2.1 As soon as it is informed of the issuing of a compliance certificate by the receiving CB, the sending CB, shall notify the operator that it terminates the certification agreement it has with the operator and that it will no longer monitor the compliance of its operation.
  • C.10.2.2 The sending CB shall require the operator to return any documents confirming the organic certification (such as certificates and attestations) that were previously issued by the sending CB to this operator as per section 13 (2) of OPR and stop immediately the use of any labels or advertising which identify the sending CB on products they market.

C.11 Requirements When a CB Issues Attestation of Compliance

This section is to address situations when a CB accredited by CFIA provides a formal "Attestation of Compliance" to service providers who perform contractual work for operators with certified product and where the service is not eligible for certification under section 14 of the OPR. An attestation of compliance will recognize the services as being in accordance with CAN/CGSB 32.310 and 32.311 to maintain the integrity of the organic product and eliminate the need for multiple inspections resulting from verification for the certification of the final product every time a different operator contracts the services.

An attestation of compliance is a written document issued by a Certification Body confirming that the provision of a service through a particular activity taking place within the production or manufacturing process of a certified product is in full accordance with CAN/CGSB 32.310 and 32.311 as prescribed in the Organic Products Regulations, 2009.This means that although the service provider does not hold a certification, the Certification Body has verified that the product subjected to this service remains compliant with the CAN/CGSB 32.310 and 32.311.

C.11.1 Scope

An "Attestation of compliance" shall be applicable for the following types of custom services:

  • C.11.1.1 The services identified as being exempt for certification in section 19 of the OPR, i.e."The slaughtering of organic livestock, or the transportation and storage of organic livestock or an organic product".
  • C.11.1.2 Other custom services for bulk product such as seed cleaning where the ownership of the product remains with the primary producer.

C.11.2 Procedure for issuing attestation of compliance under COR

  • C.11.2.1 The CB shall have written procedure for verifying compliance of the service offered.
  • C.11.2.2 The CB shall follow the steps outlined under C.3 of the COO Operating Manual as applicable to the service offered. At a minimum the CB shall:
    • C.11.2.2.1 require the service provider to complete an application form;
    • C.11.2.2.2 request an organic plan and relevant documents which demonstrate how the integrity of the organic product is maintained;
    • C.11.2.2.3 verify compliance to CAN/CGSB 32-310 and 3.11as applicable to the service offered;
    • C.11.2.2.4 conduct an annual inspection at a time when organic product is being handled or according to C2.4.2.
    • C.11.2.2.5 conduct non-compliance follow-up according to C.2.6.
  • C.11.2.3 The CFIA accredited CBs shall:
    • C.11.2.3.1 issue an "Attestation of Compliance" using the template included in the Appendix 1 of the COO Operating Manual;
    • C.11.2.3.2 suspend or cancel an "Attestation of Compliance" as required, according to C2.10.
  • C.11.2.4 The CFIA accredited CBs shall accept an "Attestation of Compliance" issued by any CFIA accredited CB as meeting the OPR requirements for maintenance of integrity and shall not require any further verification
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