Why does the LCBO require certificates proving organic certification?
The Canadian government implemented
organic regulations June 30, 2009 requiring that sellers of goods bearing
an organic claim have proof on file to back up that claim. The
LCBO requires that the proof be in the form of a document from the organic
certification agency that certified the product as organic.
What organic standards does the LCBO accept?
The Canadian organic regulations require that all products bearing an organic claim meet the Canadian organic standards or a standard officially recognised as equivalent by the Canadian Food Inspection Agency (CFIA). At this time, only the National Organic Program standard of the USDA has this equivalent standing.
Because the standard came into
effect in 2009, products marked with vintages of 2008 or earlier may
be accepted if they meet another organic standard (e.g. IFOAM, CEE 2092/91).
Why is the LCBO enforcing this now when CFIA has a two year phase-in period?
CFIA does not have a phase-in period: it is currently enforcing the regulation. During the initial two years of the regulations, CFIA is taking an educational approach that informs a violating producer of the regulations and sets a deadline for compliance. Starting July 1, 2011, CFIA will be taking more stringent action.
The LCBO policy during this
period is to reject new listings that do not meet the requirements and
to use an approach similar to CFIA with current suppliers that do not
meet the regulations.
The LCBO rejected the certificates that I sent as proof of organic status. What does the LCBO require?
The certificate must cover the product specifically. Most certification documents have a certificate page followed by page(s) listing the products covered. The list of products covered is essential. Preferably, the list indicates the vintages, varietal (if applicable), brandname (if applicable) and appellation (if applicable). If the products vary in the organic standards that they meet, the list must also indicate the standard met for each product.
Many certification companies do not list products with all of the desired information. In such cases, other supplementing information may be required (e.g. letter or label approval record from the certifying agency specifying the product).
The certifying agency must
be accredited for the standard that it audits. The official record
of accreditation recognition is the body that administers the standard
(e.g. CFIA for Canadian standard, USDA for USA standard).
I received a letter from the LCBO about wine made from organic grapes. What is this about?
The Canadian organic regulations do not permit any mention of organic ingredients outside of an ingredient list. CFIA has confirmed that “made from organic grapes” and statements about organic agriculture violate the regulation.
Some wines claiming to be made
from organic grapes may qualify as fully organic in Canada. Producers
may wish to consider certifying to the Canadian organic standard in
order to label their products as “organic wine” in Canada.
My wine has USDA NOP certification at the “made with organic grapes” level. How should it be labelled?
Until the statements concerning sulphites in wine within the Canadian permitted substances list are clarified, this category of wine meets full organic status in Canada. This is because the only difference between “made with organic grapes” wine and fully organic wine in that standard is the addition of the same restricted level of sulphites allowed in the Canadian standard.
This wine can be labelled as
organic wine in the Canadian market but should not have any “made
with organic grapes” claim on the label. Unfortunately, this
means that the same label cannot be used in the Canadian and USA markets.
Why do I require a bilingual organic claim?
Canadian organic regulations require that organic claims be bilingual. The regulations have a wide definition of claim which even includes symbols. The requirement is most conveniently met by combining the claim with the common name (e.g. organic beer / bière biologique). If the claim is made several times on the labelling, only one declaration has to be bilingual. (Note that Quebec language laws may have different requirements.)
Note that if the only organic
claim on the label is the symbol of the agency or words “certified
organic by …”, then bilingualism requirements may be violated.
Also the words “certified organic by” will be taken as a claim of
full organic status in this situation. It is better to avoid this
situation and make a separate, bilingual organic claim on the label.
Why does the LCBO object to using “organic” (or a derivative of organic) in my brandname?
Such a brandname is a claim
of full organic status under the Canadian organic standard. If
the proof of organic status submitted is not for full organic status,
the brandname is not acceptable. Registration of brandname in
Canada does not exempt the brandname from requirements for claims.
Why do I have to list the certifying agency on my label?
The Canadian organic regulations
require that the certifying agency appear on the label. Alternatively,
all of the organic claims can be struck out.
Do I have to have the Canadian organic logo on the label?
No, the logo is not a requirement.
The logo can be used on the label of any product certified to the Canadian
organic standard. If the product is not produced in Canada, a
bilingual country of origin statement is required near the logo.
Your certifying agency can advise you on use of the Canadian organic
logo.
Why was my wine rejected for sulphites? The levels were within the limits in the Canadian Food and Drug Regulations.
The Canadian organic standards allow only 30 mg/L of free sulphites (FSO2) and 100 mg/L of total sulphites (TSO2) in organic wines. The LCBO applies these limits to all wines making an organic claim.