Originally shared on August 27, 2025 by Organic Federation of Canada (OFC).
The review of the Canadian Organic Standards was launched in 2023, when organic stakeholders were invited to submit petitions for changes. In May 2025, people were invited to provide feedback on the proposed changes. The 60-day public comment period just ended and now the OFC review team is reviewing the 911 comments that were submitted.
Scope of the comments
The comments came from various sources, including individual farmers, consumers, animal welfare activists, inspectors and scientists. There were also comments from organizations, such as farming organizations, environmental groups and certification bodies.
The scope of the comments varied greatly. Some people suggested minor editorial and formatting changes, such as correcting spelling and adding italics, while others expressed ideological views (e.g., wanting to “see an end to animal agriculture”).
The OFC is very pleased with this level of participation: it shows that the Canadian organic sector is vibrant, and that stakeholders care for their environment and for the food that they eat.
Next steps
The Working Group chairs are now sorting through the comments and identifying issues that need to be discussed further. Each comment will be addressed in one of the following ways:
- Accepted as is. Most of the editorial comments, for example, will be accepted as is without any discussion. More technical comments, however, will need to be reviewed by the Working Groups.
- Accepted with modifications. Several comments raise valid concerns but don’t necessarily propose solutions, or the suggested change may need to be worded differently. In these cases, the draft of the standard will be revised in a way that will reflect the intention of the comment but using slightly different language.
- Rejected. No doubt, a number of comments will be rejected. This could be because:
- The comment didn’t address a change in the standards. For example, one comment recommends banning foie gras. But Clause 6.4.6 of the 2020 Canadian Organic Standards already states “Force feeding of ducks and geese is prohibited” and there are no plans to change that.
- The comment raises an issue that was already discussed and rejected by the Working Group and Technical Committee. For example, a number of people suggest that only slow-growing chicken breeds be used for organic poultry (meat production). The Working Group had, however, already discussed this issue in depth and no new arguments were raised in the public comment period. See “Slow-growing chickens” below.
- The Working Group and Technical Committee do not support the proposal. Many of the comments will be discussed by the relevant Working Group (WG). If, after more reflection, the WG does not support the proposed change, the WG will recommend that the Technical Committee reject the proposal.
4. Noted. A number of comments don’t actually propose a change. For example, some people used the public comment period to provide positive feedback – stating that they support the proposed changes and appreciate the way the changes were presented by the OFC. All such comments will be recorded but no other action will be taken.
5. Deferred to the next review of the Standards. Even though the goal of the public comment period was to collect feedback on the proposed modifications to the standards, some people took the opportunity to suggest completely new changes. While such proposals were welcome in 2023, at this stage in the review, it is challenging to address completely new proposals. Consequently, these comments will be recorded and addressed when the standards are reviewed again in five years.
The 2025 Standards includes a new detailed clause on raising organic insects for human food or livestock feed. This prompted a number of comments including requests for more details, such as stocking densities and methods of killing insects without causing undue suffering. Given the complexity of this issue and the need for more research on this new type of production, some of these points may be deferred to the 2030 Standards Review.
A snapshot of comments
The following issues were just a few of topics that received many comments.Glue traps
The current draft of the 2025 Standards permits the use of glue traps for rodent control. Many commenters objected to the use of glue boards to control rodents because, as one person wrote, “Glue traps are inherently inhumane and indiscriminate. These devices are not designed to kill quickly — meaning animals caught in glue traps often suffer prolonged and agonizing deaths.” As well, “non-target animals including birds, reptiles, amphibians, small mammals and even companion animals have been found stuck on them in the past.”
The Processing Working Group discussed completely banning glue boards for rodents for humane reasons, but considered that such a move would “decimate the pest control tool box for organic operators too dramatically.” Instead, they added limits to the use of glue boards, stating that they can only be used “to mitigate infestations” and “the catch must be disposed of promptly and humanely.”
Given the feedback from the public, the Working Group will revisit the reference to glue boards and possibly change the standard so that they are only used as a last resort.
Slow-growing chickens
Change in broiler chicken weight between 1957 and 2005
Approximately fifty comments suggested that only slow-growing meat chicken breeds be used for organic poultry production. As one commentator stated
“Healthier strains of birds bred for wellness, not maximum yield, help prevent both physical suffering and genetic bottlenecking. Selecting birds solely for fast growth creates serious welfare concerns; including skeletal disorders, heart failure, and reduced mobility; and it narrows the gene pool, making the entire industry more vulnerable to disease outbreaks and climate stress. By prioritizing traits like resilience, slower growth, and leg health, we support both animal welfare and long-term sustainability in agriculture.”
Clause 6.2.1 of the 2020 Standards already states: “Livestock breeds, strains and types shall be a) suitable for, and able to adapt to, site-specific conditions within the local environment and production system; b) known for their absence of disease and health problems, specific to breeds or strains; and c) recognized for their vitality and resistance to prevalent diseases and parasites.” This clause has not changed from the 2020 standards (except for a change in the numbering).
However, almost all large-scale organic poultry producers use the standard fast-growing breeds, such as Cornish Rock, Ross or a cross of these (collectively known as “Meat Kings”). The Poultry Task Force reviewed a petition to add a requirement for slow-growing poultry breeds. After conducting research and lengthy discussions, the Task Force and the Livestock Working Group decided to reject the petition for the following reasons.
“The North American consumer demands a bird with conventional broiler genetics so there is very little market for slow-growing breeds. They are also not available from hatcheries. Raising slower-growing meat chickens requires more space, more feed, more energy, and is therefore more expensive to produce and for the consumer, and has a larger environmental impact. Anecdotally, slower-growing breeds can have higher mortality than fast growing breeds.
“The motivation behind this petition is the welfare of meat chickens and the perception that fast-growing birds have poorer welfare. There is available peer-reviewed research that shows improved welfare of slower-growing meat chickens, but no clear consensus on the question has been reached. The other factors (economics and environment) are so significant that regulating a slower-growing bird is not recommended by the poultry task force at this time.”
As a result, the Poultry Task Force recommends the issue be revisited in the next review of the standards, at which time “a meta-analysis or comprehensive review of the literature be performed so there is more clarity on the welfare outcomes of slower-growing breeds.”
Exercise for cows
Freedom of movement is an integral part of animal welfare. For this reason, the use of tie stalls for organic dairy cows has been prohibited in new construction and major renovations since 2015.
The 2025 draft states “All use of tie stalls will be phased out of organic dairy production by December 2030. If tie stalls are used, dairy cows shall have an exercise period at least twice a week, preferably every day, for a period of at least one hour. An exercise period is defined as time when the cow is untied outside of routine handling procedures, such as milking.”
This issue provoked a strong reaction from the public. One comment stated “Many dairy cows on organic farms are kept in tie stalls, where they are tethered in one place for extended periods. This causes physical and psychological harm, including: joint problems, lameness, and mastitis; skin lesions from prolonged lying; and abnormal behaviours like bar biting and tongue rolling, linked to stress and frustration. Current organic standards require cows in tie stalls to be let out only twice a week for one hour. That’s not enough. This extreme confinement causes serious suffering and should be banned.”
The Livestock Working Group considered such arguments while reviewing the clause. However, given the tremendous cost of building new dairy barns, the Livestock Working Group recommended permitting the use of existing tie stalls to give farmers more time to construct new facilities. They also added more details about the required exercise period for cows in tie stalls.
Struvite
Struvite (magnesium ammonium phosphate) was added to the Permitted Substances List (PSL) in 2020 as a source of phosphorus for crops. The proposed change in 2025 permits the use of struvite that has been recovered from a larger pool of sources, including municipal wastewater.
According to the Crop Working Group, “as of March 2025, there are no sources of struvite in Canada that have been precipitated from liquid animal manure (the only type of struvite permitted in 2020). The only source of struvite is from the municipal waste stream source. The hope is that struvite from multiple sources will eventually become available.”
“Permitting struvite from municipal wastewater provides a source of phosphorus – which is greatly needed for alkaline P-deficient soils (alkalinity inhibits plant uptake of phosphate from many natural sources). The definition of sewage sludge (in Clause 3 of Can/CGSB-32.310) has been modified to permit struvite extracted from wastewater. It is reasonable to distinguish sewage sludge (biosolids), which are prohibited, from the wastewater that has undergone advanced treatment (this is what the commercially available struvite is extracted from).
“Struvite recovered from municipal wastewater is now approved for organic use in the European Union. This decision was made after extensive study by the Expert Group for Technical Advice on Organic Production and the EU general fertilizer commission, which found this form of struvite to be safe for humans, animals and the environment (subject to purity restrictions). The proposed listing in the Canadian Permitted Substance Lists exceeds the purity standards laid down in EU rules.”
This proposed change was controversial and many comments were submitted on this issue. Some supported the proposal. For example, one commenter stated “I am pleased to see the change to allow struvite from municipal waste water. This will allow organic grain farmers in western Canada to have access to a much needed approved source of phosphorus as these farmers have very limited available phosphorus options.”
Another stated “ I am a long-term organic farmer and very supportive of allowing the use of struvite from recycled sources including treated wastewater. There is widespread and overwhelming support amongst organic farmers in western Canada for the amendment allowing the use of struvite produced from treated wastewater.”
“Struvite from treated wastewater,” writes the prairie farmer, “will start to offer the opportunity to rebalance our nutrient budget and dramatically improve our legume production allowing us to return to growing peas, lentils and other nitrogen fixing pulse crops that are adapted to our growing region.
“Without the addition of widely and affordable available sources of P from off farm sources like struvite to the permitted substance list, wehave seriously considered whether we could continue to farm organically. The production of struvite from treated wastewater helps to lower P levels that are polluting streams, rivers and lakes and causing environmental damage. The use of struvite from treated wastewater fulfils the fundamental organic principle of recycling resources and closing the human nutrient cycle.”
However, other commenters had different opinions. Some people were concerned about the testing protocol. One person stated that the struvite products from currently approved sources (such as livestock manure biodigesters) do not achieve the level of purity required in the standard. Other comments asked for details about the type of testing required.
Organic equivalency with our trading partners in the US is another concern, as well as the risk of eroding consumer trust in the purity of organic food. For example, one comment stated “Struvite is allowed in the EU but not in the US. Challenges are related to Canada’s organic equivalency arrangements and public trust. With the Canada-US equivalency arrangement discussions underway, there is a risk that this could be identified as a critical variance.”
“ ‘No sewage sludge’ is a common claim attributed to organic production. Allowance of struvite will impact the ability to use this claim and could impact public trust, despite studies that may suggest there is no safety issue for humans, animals or the environment.”
All comments have to be considered, resolved and translated before they are presented to the CGSB Technical Committee on Organic Agriculture. This means that the Working Groups will soon meet to analyze the comments. They will focus on the comments that provide new information or new suggestions, and those that trigger a rewording or even rejection of a proposed change. After the Technical Committee reviews the comments, any changes induced by the comments will be incorporated into the drafts of the Standards. Then CGSB will launch the 30-day ballot period for the Technical Committee to vote on the drafts. If all goes as planned, Canada will have the new Organic Standards published by December 2025.
