RG-1 Regulatory Guidance:
Chapter 3 – Guidance on data requirements for feed approval and registration
3.24 Organic label claims

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, part 13 of the Safe Food for Canadians Regulations (SFCR) 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 Canadian Food Inspection Agency (CFIA) is responsible for the monitoring and enforcement of the SFCR. 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)).

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 SFCR 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 SFCR, feeds with an organic claim required registration to ensure that the product was properly certified in accordance with the voluntary Canadian Organic Standards. The SFCR  provide clear regulatory authority on the certification and assessment of products making organic claims.

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 3 categories (types) of organic claims which are permitted under the SFCR 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 (for example, "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 SFCR 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 Program of the CFIA, as it is not assessed by a certification body under the SFCR.

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 (for example,  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 (for example, 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 SFCR. 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 (that is, more than 95% organic ingredients) in accordance with the SFCR will not require registration of the organic claim by the Animal Feed Program of the CFIA with the following conditions:

Labels must:

• have the term "organic" in association with the common name of the product (for example, XX Mill's Organic Complete Feed for Laying Hens)
• bear the name of a CFIA-accredited certification body^Footnote 6
• 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 (for example, "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 to 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 body^Footnote 6
• 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 Program.

Companies will need to submit the standard feed registration information, as outlined in Chapter 1 - Administrative requirements for pre-market assessment and product registration of livestock feed, 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 SFCR. 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 Program; 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 Program 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 (that is, intra-provincial) are exempt from the SFCR. An organic claim on a feed that is manufactured and sold within a province, and that is not in accordance with the SFCR, 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, of the Feeds Regulation, 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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