Commercial Availability

How does OMRI address the commercial availability requirements for inputs reviewed to the Canada Organic Regime (COR) regulations?

By Nick Stansbury

CAN/CGSB 32.310 and 32.311 ensure there is a preference for the use of certified organic materials when commercially available. Clause 3 of CAN/CGSB 32.310 defines the term “commercially available” as the “documented ability to obtain a production input or an ingredient in an appropriate form, quality, quantity or variety, irrespective of cost, in order to fulfil an essential function in organic production or preparation.” In cases where commercial availability requirements apply, it is ultimately the responsibility of the certified operator to perform and document their search for commercially available organic forms. Documentation of that search is then verified by a certification body.   

When an OMRI Listed® product is subject to a commercial availability requirement, OMRI communicates this requirement by publishing specific restriction language in applicable listing categories. For example, the CAN/CGSB 32.311 Table 4.2 entry for Oilseed Meals includes the annotation, “[s]hall be organic if commercially available.” When OMRI reviews a crop input product containing an “oilseed meal,” OMRI will evaluate the organic status of that ingredient. If the oilseed meal is not certified organic, OMRI will list the product as ‘Allowed with Restrictions’ in the category ‘Oilseed meals – non-organic,’ which carries the use restriction, “[m]ay be used if organic sources are commercially unavailable.” 

In 2017, OMRI’s Canada Review Panel raised a question about multi-ingredient products where only one ingredient is subject to the commercial availability requirements. They questioned whether the final formulated product should be restricted. The Canadian Food Inspection Agency’s Standards Interpretation Committee has confirmed that the commercial availability requirement for a particular material is applicable when it is a component of a multi-ingredient fertilizer. Therefore, if a blended fertilizer contains non-organic oilseed meal, that fertilizer is restricted such that it may only be used if an alternative fertilizer of appropriate form, quality, quantity or variety that contains organic oilseed meal is not commercially available. 

There are many policies and standards considered during a product review, and assessing the certified organic status of specific materials is essential when unrestricted use is dependent upon organic certification. OMRI uses a published restriction to ensure that organic producers are aware when a product may only be used after a failed commercial availability search. The restriction appears on the product’s certificate, and is also visible when searching the product on OMRI.org.   

Originally published in June 2018.