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CAN CGSB 32.311-2015 (2018): Organic Production Systems – Permitted Substances Lists – Technical Overview
Understanding the Regulatory Framework for Permitted Substances in Canadian Organic Agriculture
CAN CGSB 32.311-2015 (2018) is a critical component of the Canadian Organic Standards suite, developed under the auspices of the Canadian General Standards Board (CGSB). This standard formally establishes the Permitted Substances Lists (PSL) for organic production systems, covering crop production, livestock production, and processing. Initially published in 2015 and amended in 2018, it defines exactly which synthetic and non-synthetic substances may be used in certified organic operations in Canada. The standard is fundamental to the integrity of organic certification, ensuring consistency, transparency, and traceability across all sectors of the organic value chain.
This technical article provides a detailed examination of the scope, technical requirements, implementation considerations, and compliance obligations associated with CAN CGSB 32.311-2015 (2018). It is intended for certification bodies, technical consultants, organic producers, and regulatory professionals involved in organic conformity assessment.
Scope and Purpose
The scope of CAN CGSB 32.311-2015 (2018) encompasses the listing of substances that are permitted for use in organic production. The standard applies to all organic operators, including farms, processors, and handlers who are certified under the Canadian Organic Regime. The PSL is structured into distinct categories based on function:
- Soil fertility and crop nutrition
- Pest, disease, and weed management
- Livestock health and welfare
- Processing aids and food additives
- Cleaning and sanitation products
The 2018 amendment brought important updates, including the addition of new substances, revision of use restrictions, and removal of outdated entries. These changes reflected the latest peer-reviewed science, stakeholder submissions, and alignment efforts with major organic trading partners. It is important to note that the standard must be read in conjunction with CAN CGSB 32.310-2015 (Organic Production Systems – General Principles and Management Standards), which provides the overarching management framework.
Harmonization benefit: The 2018 amendment improved alignment with the US National Organic Program (NOP) and European Union organic regulations, facilitating international trade while preserving Canada’s specific requirements.
Technical Requirements – The Permitted Substances Lists (PSL)
The core of the standard is a series of matrices that categorize every permitted substance by its origin (synthetic or non-synthetic), permitted use, and any restrictions or conditions for use. Each entry typically includes the substance name, functional category, allowed forms, and limitations. The following table illustrates representative examples from the standard (note: this is not a complete list and is provided for illustrative purposes only).
| Category | Substance | Type | Specific Use / Condition |
|---|---|---|---|
| Soil fertility | Bone meal | Non-synthetic | Must be obtained from organically raised animals; prohibited for ruminants unless from certified organic sources. |
| Pest management | Copper sulfate | Synthetic | Permitted as a fungicide; limited to specific crops and soil application; must not be used as a growth regulator. |
| Pest management | Neem oil | Non-synthetic | Permitted for use as an insecticide; must be cold-pressed and without synthetic additives. |
| Livestock health | Ivermectin | Synthetic | Allowed only for emergency veterinary treatment; strict withdrawal period of at least 90 days for meat animals. |
| Processing | Citric acid | Synthetic | Permitted as a pH adjuster; limited to a maximum of 2% of the final product weight. |
| Cleaning | Hydrogen peroxide | Synthetic | Permitted for disinfection of equipment and surfaces; equipment must be rinsed with potable water before use. |
Implementation and Certification
Effective implementation of CAN CGSB 32.311-2015 (2018) requires operators to establish a traceable record of every substance brought onto the operation. Certification bodies (CBs) verify compliance through audits that check substance procurement records, application logs, and product labels. Key implementation steps include:
- Substance inventory: Maintain a current list of all substances used, their intended purpose, and the relevant PSL entry number.
- Supplier verification: Ensure that all purchased substances are certified organic compliant or explicitly listed in the PSL.
- Training: Educate all staff responsible for applying substances about the restrictions and recordkeeping requirements.
- Risk assessment: Identify potential contamination routes (e.g., drift from non-organic fields) and establish buffer zones where needed.
Best practice: Operators should subscribe to the CGSB notification service to receive immediate alerts when PSL amendments are published. The 2018 amendment introduced a transition period of six months for new restrictions to allow operators to adjust their supply chains.
Compliance and Auditing Considerations
Non-compliance with the PSL can result in certification suspension or revocation. During an audit, CBs examine several key areas:
- Documentation completeness – Are all substance purchases and applications recorded? Do records include batch numbers, application dates, and withdrawal periods?
- Use compliance – Does each substance have a clear permitted use condition? Are there any exceedances in application rates or frequency?
- Substance prohibitions – Are any substances on the operation that are not on the PSL or that are explicitly prohibited?
- Cross-reference with CAN CGSB 32.310 – Is the overall organic management plan consistent with the permitted substances used?
Warning: The use of a non-permitted substance, even inadvertently, must be immediately reported to the certification body. Failure to disclose such use can be treated as a critical non-conformity and may trigger a mandatory recall of affected products.
Future Outlook
The CGSB is expected to continue periodic revisions to the PSL to reflect evolving agricultural science, environmental concerns, and trade dynamics. The standard’s alignment with international counterparts will remain a priority. The 2018 amendment set a strong precedent for responsive, science-based updates that protect organic integrity without stifling innovation.
Attention to recordkeeping: Auditors have identified that a significant proportion of non-compliances result from poor documentation rather than malicious use. Implementing a digital substance management system can greatly reduce risk and audit burden.
Frequently Asked Questions
Q: How often is CAN CGSB 32.311 updated?
A: The standard is reviewed on a five-year cycle, but the CGSB may issue amendments more frequently if urgent issues arise. The most recent amendment was in 2018; the next full review is scheduled, with stakeholders consulted through public comment periods.
A: The standard is reviewed on a five-year cycle, but the CGSB may issue amendments more frequently if urgent issues arise. The most recent amendment was in 2018; the next full review is scheduled, with stakeholders consulted through public comment periods.
Q: Is the PSL fully harmonized with the US National Organic Program?
A: No, but the 2018 amendment significantly increased alignment. Differences remain in areas like livestock health treatments and certain processing aids. Operators exporting to the US must also comply with the USDA NOP requirements, and a separate equivalency arrangement is in place.
A: No, but the 2018 amendment significantly increased alignment. Differences remain in areas like livestock health treatments and certain processing aids. Operators exporting to the US must also comply with the USDA NOP requirements, and a separate equivalency arrangement is in place.
Q: What should I do if I need to use a substance that is not on the PSL?
A: The standard does not allow for ad hoc approvals. Operators may submit a petition to the CGSB for consideration in a future amendment. In urgent situations, a temporary variance may be available through the certification body, but this is rare and strictly controlled.
A: The standard does not allow for ad hoc approvals. Operators may submit a petition to the CGSB for consideration in a future amendment. In urgent situations, a temporary variance may be available through the certification body, but this is rare and strictly controlled.
Q: Does the standard cover packaging materials?
A: No, packaging materials are not included in the PSL. However, they must not compromise the organic integrity of the product. Recycled content and avoidance of synthetic coatings are recommended but not mandatory under this standard.
A: No, packaging materials are not included in the PSL. However, they must not compromise the organic integrity of the product. Recycled content and avoidance of synthetic coatings are recommended but not mandatory under this standard.