Microbial Substrates

Are genetically modified substrates or growth media permitted in organic production under the Canadian organic standards?

By Shannon McCormick

Genetically modified substrate or growth media are allowed in Canadian organic production only if the material is removed first from the permitted substance, and if a non-genetically modified alternative is not commercially available. (Consumption, and physical methods such as filtration or centrifugation, are examples of generally accepted events which separate or remove the substrate or growth media from the microbial product.) This requirement is documented in CAN/CGSB-32.311 (the Permitted Substances List, or PSL), specifically clause 4.1.3 (crop production), 5.1.2 (livestock production) and 6.2.1 (processing substances). These additional standards do not apply to permitted substances listed in PSL Tables 7.3, 7.4, 8.2 and 8.3. Substrate or growth media that remain in the final product must be listed in the relevant PSL Table, and must comply with the GE prohibitions in clause 1.4 of CAN/CGSB-32.310. 

Evaluating microbial substrate and growth media for genetic modification status under the Canada Organic Regime (COR) standards can be challenging. OMRI has the added challenge of communicating our determinations publically. We approach these reviews in the following ways. First, we require a declaration of the GE status of all substrates or growth media. Even when the substrate or growth media is removed, OMRI requires applicants to identify all ingredients within them. For ingredients at high risk for generic modification, a GE declaration is required directly from the manufacturer of the high-risk material. OMRI considers the following materials as high-risk: nonorganic alfalfa, canola, corn (and corn byproducts), cotton, papaya (papain), soy (including vegetable protein), sugar beets (sugar and molasses), squash, yeast, enzymes, and all microorganisms. 

The second way OMRI addresses the GE substrate standard is by assigning a commercial availability caution to final products that use GE substrate or growth media in the production of a microbial product. This caution appears on the certificate of the OMRI Listed® product, on the OMRI website, and in the OMRI Canada Products List^©. Similarly, if the applicant does not know or cannot obtain information about the GE status of a high-risk substrate ingredient, the applicant may accept a commercial availability caution. This caution states that the product was produced using GE substrate or growth media and, if commercially available, a non-GE alternative shall be used. This is the method OMRI uses to ensure our findings are communicated publicly so that the organic producer and their certifier can complete their work.

To be clear, this caution is only applied if the GE substrate or growth media is considered removed from the final permitted substance. OMRI will only assess whether substrates contain GE material, and does not assess commercial availability. Commercial availability assessment must therefore be documented by the organic producer and verified by individual organic certifiers. Input manufacturers who wish to remove the commercial availability caution may submit a product change request and documentation that shows that the ingredient(s) that will be used are non-GE. Organic producers should always check with their certifier before using a new input product.

This article was originally published in the fall 2017 edition of the OMRI Materials Review newsletter, and was reviewed and updated in June 2023 by Technical Director Doug Currier.