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Top reasons OMRI Canada might reject an application

By Evan Thomsen

The OMRI Canada review program turned four this year, and during those four years we have seen a number of recurring reasons why OMRI might not allow products for organic production under the Canada Organic Regime (COR) regulations. There are several points of compliance that determine the allowance of input materials; some are OMRI policy, and some are mandated by the regulations in CAN/CGSB-32.310 and CAN/CGSB-32.311. Below is a list of some of the common reasons why products do not end up on the OMRI Canada Products List© (OCPL):

  1. The material is not identified in any Permitted Substances List (PSL) table: The COR regulations use a “closed list,” meaning that all compliant inputs are noted in the PSL tables at CAN/CGSB-32.311. If the material isn’t in the PSL table, it’s not allowed in organic production.

  2. The material is identified in a PSL Table, but not in the relevant table: The COR PSL tables are each specific to a class of organic production (crops, livestock, etc.), and further segregated into uses (crop fertilizers, crop pesticides, livestock feed, livestock health care, etc.). PSL entries are generally not transferrable to other uses or production classes unless the specific entry references a different PSL table. An example of this is colostrum, which is allowed at PSL Table 5.3 for use in livestock health care products and production aids, but is not allowed at PSL Table 5.2 as an additive in livestock feed.

  3. The PSL table includes an entry for the substance, but it limits the allowance to specific forms of the material: For example, PSL Table 4.2 allows manganese as a soil amendment in organic crop production, but limits the source of manganese to manganous oxide and manganese sulphate. Manganese that is derived from any other source would be prohibited.

  4. Products of Genetic Engineering (GE) are present: The COR regulations at CAN/CGSB-32.310 prohibit all products of, and materials from, genetic engineering. Refined substances such as oilseed meals and molasses are prohibited from using GE ingredients.

  5. Lab analyses are not compliant: The PSL tables often specify maximum limits for content such as heavy metals, pathogen loading and foreign matter. Products that test above the maximum allowable limit are prohibited.

  6. The company is unable to get required information from an ingredient supplier, and the product is forfeited: A status of “forfeit” means that the review ends and the product is not listed in the OCPL. The most common reason for a forfeited review is an expired deadline for submitting necessary information.

  7. More information is needed to help review an OMRI Listed® ingredient: Different ruling bodies and classes of organic production require different documentation to ensure compliance. A product may include an ingredient that is OMRI Listed, but additional information is needed from the ingredient supplier to verify compliance. OMRI Listed suppliers are not required to provide information when an applicant uses their product as an ingredient, though many are willing to work with OMRI to provide the necessary information.

  8. The product is out of scope: Hydroponic and aeroponic production are both prohibited in the COR regulations at CAN/CGSB-32.310 clause 7.5.3. Thus, products labeled exclusively for use in hydroponic or aeroponic production are outside the scope of OMRI’s review program.

  9. Beyond resolution: Products affected by an issue that is considered “beyond resolution” are not reviewed by OMRI. A list of beyond resolution issues is available online at https://www.omri.org/faq.

These are just a few examples of reasons why a product might not become OMRI Listed. Knowing the organic standards before applying, paying attention to OMRI’s policies, and managing deadlines are all important for a successful application.