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COR Questions and
Answers
On December 21, 2006, the Organic
Products Regulations of Canada were published bringing in requirements for
another major market for organic produce. The new requirements have
implications for organic operators and their certification bodies worldwide
and come fully into force from December 14, 2008.
The IOAS is further widening its service to organic certifiers and expects
to be offering accreditation against the Canadian rules as early as May
2008. The following summarises some of the key issues relating to the
Canadian rules.
WHO HAS TO BE ACCREDITED
Q. Will I have to be accredited to work as a certification body (CB) in
Canada?
A. Yes
Q. Will I have to be accredited to certify product exported to Canada?
A. Yes
IOAS ROLE
Q. By whom?
A. Legally by the Canadian Food Inspection Agency (CFIA) but practically by
an accreditation body (AB) that has an agreement with CFIA for this purpose.
Q. Is the IOAS approved by the CFIA?
A. Yes. We were informed officially by
letter from CFIA on April 10th
EQUIVALENCE AND RECOGNITION
Q. Will this import accreditation be based on equivalence or compliance?
A. The regime requires compliance - i.e. you will have to certify the
product against the Canadian standards not to some equivalent standard.
Q. Is there no country to country recognition?
A. Yes there is such a provision and it is based on equivalence. However it
would be reasonable to expect that Canada would concentrate on establishing
such an agreement first with the US and the EU as these are their major
trading partners. Canada may forge agreements with other countries with
implemented organic regulations but these may not have occurred before the
implementation date of the regulation and may take some years based on
experience elsewhere in the world. Of course there is no guarantee that the
US or EU negotiations would be without difficulties
Q. If a mutual recognition is established with my country does that mean we
will be able to certify within Canada
A. No. To certify within Canada you must be accredited by CFIA through an
approved accreditation body.
Q. If a mutual recognition is established with my country does that mean
this will cover operators we certify in other countries.
A. No, unless your accreditation body is approved by CFIA and they include
surveillance of your foreign activity.
Q. If the IOAS is approved for both domestic and international would it be
one and the same accreditation?
A. Yes. The accreditation would be different only in so far as a
certification body applying for both would be placed on two official CFIA
lists. There would be one evaluation as the basic requirements are the same
- there are additional and different administrative requirements for
domestic compared to imports but the accreditation requirements are the same.
WHEN DOES IT COME INTO FORCE
Q. When is all this likely to happen?
A. The CFIA have planned a staged approach - namely that the ABs will be
approved first then the certification bodies will get accreditation and then
the operators will be certified. The approved AB list is due out in April
2008 after which CBs can apply for accreditation. Current clients of the
IOAS can already apply for accreditation under the COR. New clients will
have to wait until the approved list is published. The implementation date
for the Regulation is December 14th 2008.
THE NORMS
Q. I haven't read the standard - what is it like?
A. It is very similar to IFOAM and the current EU regulation and therefore
also Codex. If you have read this far into this document you probably need
to read the standard
Q. What about the criteria?
A. They are clearly based on ISO Guide 65 with some additional requirements
from both IFOAM Norms and Quebec requirements. If you are already IFOAM
accredited you would be familiar with many of those additional requirements.
CURRENT IOAS CLIENTS
Q. If I already have an IFOAM or an ISO Guide 65 accreditation with the
IOAS, how much will you be charging for the Canadian accreditation?
A. The 2008 IOAS fee schedule does not distinguish between accreditations;
you can add and mix and match as you please. The initial application would
cost US$2000 plus the additional visit costs (an extra day or two). The
annual fee will be US$500 with no percentage charge.
Q. Do you realize how cheap that is?
A. Yes we do. We are able to do this because there is considerable overlap
between the different accreditation requirements and we have developed
information handling systems to take advantage of that fact. Plus we are a
non-profit organisation here to perform a service.
Q. I am not due an IFOAM (or ISO guide 65) reevaluation in the next few
years. Will I have to have a full evaluation including site visit for
Canada?
A. Our understanding is that you will not. We will include additional checks
in our surveillance activity (whether you are in a bye year or visit year).
We may however bring forward your next re-evaluation based on the extent of
your Canadian activity.
NOT CURRENTLY AN IOAS CLIENT
Q. And if I don't have any existing accreditation with the IOAS?
A. You may apply to IOAS from the date of publication of the CFIA AB list.
As a first accreditation with the IOAS the application fee is US$5000 plus
visit fees. However any additional accreditation (IFOAM, ISO65 or Europe)
can be added at minimal cost and of course you will receive all the
knowledge and understanding for which the IOAS is well known.
Q. What kind of ongoing accreditation is involved?
A. The current text calls for reevaluation at least once every 5 years with
surveillance visits every two years (one year if there are outstanding
conditions). For current clients with accreditation with 4 year cycles the
Canadian evaluations will be synchronized with those cycles
For more information, contact info@ioas.org
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Last updated:
06/05/2008
Letter from CFIA
20kb
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