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To Certify or Not To Certify: The perspective of small-scale organic farmers

October 30, 2014

3.3  farmer's market

Local +organic = a win-win situation for growers, consumers and the environment.  

Small-scale organic farmers represent the face of the Canadian organic industry—at the farmers’ market, CSA drop-off and at the restaurant back door. Today, public on-farm exposure often happens through harvest days and other events offered by small farms.

Many of these farmers, however, are not certified organic. The typical small-scale farmer depends on direct marketing relationships—their sales pitch cultivates and educates buyers interested in supporting environmentally sound farming methods.  For these growers, the expense and effort of certification isn’t justifiable, since attaining certified organic status doesn’t significantly increase sales or the trust already earned from buyers.

In the spring of 2014, the Working Group on Small Scale Organic Certification (WGSSOC) administered a survey to small-scale farmers. 200 responses were received.  The data highlights how the current “one size fits all” model of organic certification is often not feasible for small-scale operators.

Meanwhile, “opting out” is far from optimal. The split among organic producers (certified vs. non-certified) confuses customers, who are still learning what organic agriculture is all about, and why it matters.  Survey respondents cited concerns that the  decision of small farmers not to certify has hindered the growth of the organic movement.

Building on its survey data, the WGSSOC has drafted two organic certification models that aim to be attainable for a small-scale producer focusing mainly on direct sales (farm-gate, CSA, farmer’s market, etc.): the Peer Certification Model and the Self-Declaration Model.

For both models, features are:

  • Simple online application
  • Can be used only in jurisdictions without a provincial organic regulation.
  • All documentation pertains to small, diversified operations engaging in direct sales.
  • Bureaucratic overhead is reduced.


“Certified Local Organic” (CLO) The Peer Certification Model

Annual on-farm inspections are conducted by peers. Compliance with the Canada Organic Standard is verified online by a third-party certification body.

  • Records and verification reports are accessible and available online.
  • Annual certification costs  based on gross sales of organic product.
  • BUT: Peer verification of farms in remote areas may be difficult to arrange.

Organic Affidavit (OA)”—The Self-Declaration model

Producers publicly pledge to understand and follow the Canada Organic Standard.

  • Applications and pledges can be viewed online.
  • Low annual certification costs.
  • BUT: Model may not be accepted by the rest of the organic producer community.


Would the self declaration or peer review model be something that feels more appropriate for your farm? Do these models address the concerns and needs you have around certification? If so, which one would be the most appropriate?

Your input will inform WGSSOC’s presentation of these models at the Technical Committee on Organic Agriculture meetings in December 2014 and April 2015.

Needing additional information? Click here to access documentation about Small-Scale Certification.

51 Comments leave one →
  1. November 5, 2014 10:12 am

    glad to see this is up and going forward

  2. Sarah Harrison permalink
    November 6, 2014 10:19 am

    It is fantastic that this issue is being addressed, however I do not believe that you are reaching one of your goals of reducing consumer confusion between certified and non certified. If I understand correctly you are now looking at adding more ‘options’, how will we educate consumers on such a wide range? And who will monitor all of these options? I feel that it adds to the ‘muddy-ness’ of the organic sector in Canada. Perhaps instead of re-inventing the wheel we need to lobby the provincial goverments who do not have regulations around the use of the term organic. Yes, there is cost and effort involved for small scale farmers to become certified. But there is a cost to doing business. I feel the proposed 3 tier system de-values those of us who are certified.

  3. Rob Campbell permalink
    November 6, 2014 1:18 pm

    Thank you for addressing this issue.

    I believe third party verification is the key attribute that distinguishes organic certification from most other types of production (see As such, I think even the Self-Declaration Model should including random inspections. Peer review may be adequate, but beware of blurring the lines between certified organic and certified naturally grown.

    On a different note, if local small-scale organic production is important to moneyed stakeholders (e.g. the Government of Ontario’s Local Food legislation), perhaps they could subsidize certification costs for producers that meet their policy objectives.

    I like the gross sales basis for calculating fees, but I also understand how certification becomes more complex and therefore more costly with each new operation. The flat fees for certifying additional operations discourages organic producers from testing new ventures. Given that cost driver, it is unclear that the gross sales basis will result in lower certification fees.

    Assuming inspection costs are a major component of certification expenses, perhaps part of the solution is to inspect smaller producers less than annually. For example, if 1/3 of small producers were inspected each year, that could significantly reduce certification costs while keeping third party verification. To increase compliance the small producers should be selected randomly; that way each producer never knows if they will be inspected this year.

  4. November 6, 2014 2:31 pm

    As each year ends I find myself debating whether or not to certify. Miserable destructive winter, fruit harvest down, price of certification up = disheartened. A small scale system would be welcomed right now. Peer review would be good in our case – as I am moving towards a food forest system – harvesting crops that planted themselves…there is no form for that.

  5. November 6, 2014 2:52 pm

    We have also been debating whether or not to go organic with our small-scale vegetable farm but it is only out of frustration against some who claim to grow organically. The cost that goes into our feed, seeds, compost, and soil mix (for starting seedlings in the greenhouse) is easily double what our competitors pay. Also, from an ethical standpoint, we end up refusing to use some of the organically approved pesticides, going beyond conventional organic standards. We have started the process with a certain organic label, who, we were told, were very reasonable. Hours of office work later, I feel no closer to being complete, and have found out that since we are in a rural part of Ontario, the cost is nearly double what we had budgeted. The application process itself has been costly, due to the time I’ve had to put in (we grow 46 different vegetables, some in greenhouses, and raise pastured poultry), and the yearly fee is steep for us, but the inspection is what put it over the edge. We simply do not live in a wealthy area where people are willing to pay what the food is worth. To add the label would mean losing many of our customers, as we would have to increase our already “steep” prices. That being said, when we shop, we only buy organic, as consumers we have no other way of knowing the practices miles away from us. For all of these reasons, we are 100% supportive of a Peer Certification Model (CLO) which is far better suited for a small-scale grower who ONLY supplies the local markets.

    • Susan Linkletter permalink
      June 2, 2015 9:08 pm

      You should look at other certifiers. My operation is similar to yours and i dont find my certifier expensive and the forms are not difficult to fill out. It will require a good afternnon of your time to fill the forms out the first time. Modules are easily updates for any changes that you make to your production system. I am with OCIA.

  6. November 6, 2014 6:16 pm

    This is a great topic, thanks for creating this forum. We are farming on 1.5 acres, and sell direct to customers at a Farmer’s Market and CSA. I can think of only a couple of our customers who buy from us specifically because we are certified. We also question the decision to certify each year; and as cumbersome and time consuming as it can be, it always reaffirms my confidence in the organic label when I know that other producers, no matter how large or small, are going through the exact same process.

    I’d like to respond to a couple of the points raised already. First of all, when we were with a different CB where the cost was based on our earnings, I felt we were paying too much, especially when I learned that a large farm (over 100 acres) was paying practically the same amount as us. So we switched to a different CB, where our rate is based on our farm size, and not our profits — making the rate much more reasonable, and a justifiable cost of doing business.

    I also agree that creating new classifications of ‘organic’ would add to consumers confusion about what the word actually means. I was a bit frustrated this year to learn about the different ‘levels’ of organic for prepared/processed foods (i.e. ‘certified organic’ if at least 95% of the ingredients are certified; only ‘organic’ if at least 70% of the ingredients are organic, etc). When we were becoming certified, we heard from others that there is no difference between ‘certified organic’ and ‘organic’, there is only one ‘organic’ and it’s certified. It all seems to water down the confidence consumers have when there are different classifications of organic. And since we rely on the organic label ourselves when we shop, I feel it’s important to offer our customers the same peace of mind when they buy from us.

    Of course, we still encourage customers to ask each farmer about their growing practices, because as we all know, just because we are under the same label doesn’t mean that we manage our farms the same way. But at a minimum there are things we all have in common, and that’s important for customers to know.

    Another farmer friend mentioned that their reason for certifying was ‘to be counted.’ Provincial and Federal governments only count ‘certified organic’ farms when counting how much land is certified, which is also the numbers/stats they use when deciding how large of a piece of the budgetary pie the organic sector should receive. They don’t count farms that are using ‘organic practices’ ‘following the organic standards’ or are ‘sustainably grown’.

  7. Jeff and Joanne Greenberg permalink
    November 7, 2014 10:21 am

    We can certainly understand the desire to accommodate the needs of the important sector of small, organic farms. We have been certified on our small farm since its inception, including going through the appropriate transition period. Our comments below are based on our commitment to the organic standards and on our observations at farmers’ markets and garlic festivals regarding the loose, and often deceitful use of the organic claim.

    More and more consumers are looking for assurance that their food is safe to eat and often that it has a small environmental footprint. The certification of a farm’s organic practices was meant to provide one level of assurance of the former. Without provincial or federal regulation of the term “organic” or “natural”, however, consumers have been confused by “non-certified organic”, “organic”, and other terms being used loosely and, frankly, without real meaning. Been to a garlic festival recently? How many vendors say they’re organic without any knowledge of what that means? They’re simply coat-tailing on the hard work that others have gone through over many years as a way of shamelessly extracting more money. Very few customers are equipped to understand whether a farmer’s following the standards even if they were to visit that farm, let alone buy from them at a market or through a third party. Knowing your vendor is very important and buying locally is enhanced by that knowledge but it’s insufficient when trying to understand whether that chicken you’re buying is being fed GMO corn and soy and most consumers don’t know any other question to ask except “do you spray?” While most farmers are honest about their practices, there are many others who are not.

    The models proposed have the same risk of both abuse and the creation of customer confusion as we have today, if not more. These models dilute the hard work and commitment that many of us have made to stay certified and would remove any incentive for small producers to remain so. It’s a giveaway to big organic who will be the only ones left using the logo and certified brand and once the small producers have opted out, big ag and big organic have more control.

    Better would be to work to change a few things that would make a bigger difference. Putting a provincial regulation in place in Ontario (and other provinces where none exists) along with financial and practical support for the small producer to gain certification would allow one label to exist, without confusion.

    Financial assistance for transition exists in many jurisdictions throughout the world and would be of great benefit for small Canadian producers as well. In Ontario, anyone below the FBR threshold of $7,000 might have their fees entirely covered to ensure farms at all levels are able to participate in becoming certified.

    While we have not found the paperwork to be onerous, it was helpful for us to have taken the EFAO transition course that first year to feel comfortable getting started. Each year we’ve gone through an increasingly simple but meaningful winter exercise to get our paperwork done and think again about our practices for the upcoming year in relation to the Canadian Organic Standards. Support of programs like those by the provincial governments would be helpful.

    We feel strongly that one standard for the claim of organic production is in the interests of both farmers and consumers and that further dilution would make the claim meaningless to both.

  8. November 12, 2014 3:50 pm

    We also have been dealing with the conundrum of wether or not to certify. We are a small scale one crop farm: Garlic & value added products. In our case the great majority of our customers and vendors don’t care wether we are certified or not, they are more interested in the fact that it is local and a superior product to what is out there in stores. In our surveys it seems that the wholesale and retail prices of our produce/products are the same regardless of being certified or not. Our stumbling block for certification has been the fact that we can’t charge more for our product to absorb the hefty cost of certification. We started the process several years ago, dropped it because the cost outweighed the benefits for us . However, we are now going through the process of certification again… I guess we are just doing it just for “decoration” and to prove that we are certified if we are ever asked. I am sure there are many more small businesses like ours that are wrestling with this same dilemma.

  9. D Lunn permalink
    November 17, 2014 2:36 pm

    Honestly wonder why farmers are not converting? It is the hassle, the cost, and the time of paperwork,. not the commitment to the environment. As conventional farmers since 1980 we followed most of the ‘organic’ practices anyway and became certified organic in 2008 on 100 acres. We are also farming conventional on other farms, although they are non GMO, as we have not mastered more time to do more than 100 acres organic with just ourselves as labour. The process of certification is burdensome, costly, and frustrating. Many farmers we know are organic, and are dropping the certification as the consumers they sell to already have their confidence. We want to keep it up but ran into more frustration this year with ‘parallel production’ this year b/c of our other farms, even with all the proof necessary and all the careful cleaning and inspection of equipment. The questionning and extra cost came from the head office in Sask and the inspector who came clearly indi cated his frustration as well. Until less burdensome red tape is available, the trend of uncertification may continue.

  10. November 18, 2014 12:01 pm

    Reblogged this on Balanced Meals Nutritional Strategies To Live By.

  11. Joyce Kelly permalink
    November 19, 2014 2:56 pm

    This is a way of allowing smaller producers to still be certified without paying as high a cost. Without the excuse of the certification being too expensive there should be more producers actually following the guidelines of the Canadian Organic Regulations, and could be a stepping stone to becoming fully certified to export to other provinces or countries.

  12. Susan Linkletter permalink
    November 24, 2014 7:35 am

    I agree that certification costs too much for small farms, and the financial benefits of being certified organic have been diluted – locally grown commands the same price as organically grown now. There is no easy solution though, the same standards and procedures need to be applied to farms if organic is going to mean anything. Perhaps a certifier will someday recognize that there is an opportunity here and lower fees for small producers to make it more affordable. Small farmers eventually become bigger farmers, so a little up front investment might be worth the long term pay-off.

  13. December 1, 2014 12:23 pm

    Great thread with many excellent points. We have been certified for a few years and have also contemplated dropping it every year. The reasons: cost- we price our products according to the minimum we believe we deserve for offering them not because we are certified, the paperwork necessary for inspection which doesn’t always coincide with the paperwork we would do normally to properly manage things. However, i don’t believe the answer is to create different levels of organic certification which would add to all the confusion already out there regarding food. It would also be another opportunity to try and discredit the organic movement by opposing forces saying that peer inspections for example are not honest. I like the idea of inspecting smaller producers less than annually maybe once they’ve reached an anniversary date and somehow lowering cost to add extra areas to be certified…we don’t certify our eggs or poultry but raise them to organic standard but the cost is just too much. I also think that we should receive some subsidy or break from the government for taking on the time and cost of protecting the environment and peoples health as opposed to conventional farms who pass the buck onto others through pollution, health problems etc….

  14. A Grant permalink
    December 1, 2014 3:58 pm

    As a small scale, certified organic farm, I too have struggled with the cost and subsequently found a certifier with a lower cost for a small diversified farm category. The disparity between the percentage of profit versus certification cost of the small scale farm to the large scale farm is quite shocking. I’ve calculated a 35% cost vs profit for small and a low of 3% cost vs. profit for large. This alone should encourage CB’s to take a closer look at their fee structures and certainly, provincial leaders should be considering a cost share program to alleviate the disparity.

    I do not believe that adding layers to the current system will do much more than further create confusion for the buying public or that such a system would necessarily attract the non certified. As an organic inspector with training and experience under my belt, I fear the peer review, thus peer inspection model is weak merely because an organic inspector would not be doing the review.

    Self declaration is not worthy of consideration from my point of view and my thoughts on both models relate to the ease of abuse and weakening the current model and no way meant to insult those who farm with integrity. Already there are folks in our midst who claim to be organic who may have a vague understanding of organic principals but have no idea how that relates to all aspects of what we do. Merely using manure does not make a farm organic. And then there are those who just lie about it.

    We need all provinces to adopt the regulation as law and provide cost sharing programs to address the disparity between small and large operations (or the CB’s address their fee structures). Once this utopian world exists and there are still farmers opting out, then perhaps the reality is, regardless of what we do there will always be those who won’t participate. Creating other options will not eliminate administrative oversight or the cost associated, nor the need to invent yet another wheel.

  15. Waverly permalink
    December 1, 2014 7:53 pm

    These would be excellent systems to have in the future and I am excited to see what comes of this.

    I do – however – think that if a farm decides to opt out of certifying themselves, it is important to be as transparent and informative to their customers about their practices as much as they possibly can.

    We are a new, small-scale & organically grown farm that prides ourselves on following all of the guidelines of a certification — one of which that is simply not feasible for us to maintain each year. With that being said, we take as many different approaches as we can to let our customers know what is going on at our farm through weekly e-mails, facebook page, instagram and website. I truly feel that this has helped to create great relationships with customers and a trust that we are doing what we can to stay organic.

  16. December 4, 2014 11:56 am

    Consumer confusion is continued in this manner. It would be better to work at levelling the playing field, making it more equitable by giving certified organic growers/processors a tax break that would equal the extra cost of being organic – the cost of certification and any added costs like contractor fee differences.

    • Rob Campbell permalink
      December 5, 2014 6:42 pm

      A tax credit would be better than a tax deduction to level the playing field since a tax deduction would have no value to the many small farms that report net losses on their income tax returns (whereas a tax credit would increase the amount of the refund). This could be inserted at the federal or provincial level.

  17. December 4, 2014 1:17 pm

    We are certified organic (for animal and crop production and soon for processing too) and are able to recoup the cost of certification through our prices. I believe that neither the peer certification nor self-declaration models will reduce customer confusion but rather will increase it. I have seen many farms that call themselves organic and really believe that they are yet I am often (not always) appalled at their practices. I also see many customers who have real definite health concerns and are trying to alleviate them by consuming organic food. It saddens me when I see these customers purchase products at organic prices, believing them to be organic, yet they contain GMO and conventional ingredients. For a standard to actually be a standard it needs to be standardized – that is why organic farmers and processors need to certify as organic.

    We decided that we would produce organic pigs. In order to do that we had to take the step of breeding them ourselves (organic standards state that the pigs need to be raised organically from the last trimester of their mother’s pregnancy – a weaner pig purchased from another farm won’t do). The cost (and effort) of overwintering breeding stock is huge. I don’t want to have other people call their pigs organic who have simply purchased weaner pigs in the spring and fed them organic feed.

    If the peer review method is chosen – who on earth would volunteer to review their neighbour’s farm, look over all of their invoices for feed, add them up to make sure they balance with the receipts and make sense for the number of animals on the farm, poke around the kitchen, garage and barns to look for medication, inspect the compost pile, measure the housing and count the animals, etc, etc. If volunteers run out and people had to be paid then we are back to what we have now.

    Self declaration is just too open to fraud. Any farm aught to have transparency. If your customers read your website and actually visit your farm to witness your practices you don’t need organic certification – they know that you are doing what you say you are. The only reason you would want certification would be to sell at a premium to people that don’t know you. In that case you need to be certified – pay to have someone prove that you are doing what you say you are doing.

    In my opinion it would be far more effective to work with the existing certifying bodies and standards to help streamline paperwork and make the standards work better for small farms and processors.

    • Jeff and Joanne Greenberg permalink
      December 4, 2014 9:49 pm

      Well said, Karen. Reflects our position perfectly.

  18. Rob permalink
    December 4, 2014 1:18 pm

    From the point of view of a small niche market grower in the (tentative) process of gearing up production to assess the viability of my enterprise, the self-certification concept appeals. If you are a mainline business-scale operation then the cost of certification becomes relatively minor. But for those smaller growers like me, the cost is a real barrier.

    However, I would recommend against self-certification. It’s the old foxes and henhouse problem and there is no way around it. Having worked in environmental protection and regulation for decades there is no doubt that most people do not trust businesses/industries to police themselves, and with good reason. So we need third-party checks. Some have advocated tax breaks or subsidies for smaller operators to allow entry to the certified realm. I support that concept.

    Meantime the whole system needs to be simplified. I think many consumers have become distrustful of organic labelling due to the big stores/producers getting in on it, resulting suspicion, and uncertainty over what it means. My customers currently are almost all people who know me and how I operate, so they trust that my stuff is organic when I say it is, even though it is not certified. But to expand, I would need to reach others who do not know me. For this, official certification would be an asset. But for now it’s too expensive relative to my total turnover.

  19. Nancy Judd permalink
    December 4, 2014 1:27 pm

    Nancy Judd
    Please do not consider diluting the organic standards. There is a cost to being certified as with any other licencing. It would be great if there were programs to offset the cost but certified is the way to go. If the paperwork seems onerous I question how any farmer who has trouble with them could actually understand and operate an organic farm. Pressure the provincial governments to pass organic legislation and educate the consumers. Food is too cheap and we small organic producers almost never get a fair price. There is so much organic greenwash, whether it is intentional or not it undermines real organic

  20. Stuart McMillan permalink
    December 5, 2014 2:30 am

    As a super small scale certified organic operation, and as an organic inspector what surprises me is that this proposal is going forward with no one mentioning that this is a system that will not apply in BC, MB, QC and NB. As an inspector I cover a huge amount of territory across all 4 western provinces. In AB most small scale formerly “sorta organic” have become “certified organic” due to buyer demand requiring that level of transparency. In SK the direct to consumer market is pretty small and under developed. I was in the Maritime provinces last in 2003, so i can not speak well to the current situation there. But this is essentially a program for ON farmers. It will create, as others point out, greater consumer confusion along with a totally disparate set of rules and regulations from one province to another. What I feel really needs to happen is that all of the other provinces establish their own intra-provincial organic regulations and close the loop hole that CFIA involvement with the organic standard inadvertently created.

    • Jeff and Joanne Greenberg permalink
      December 5, 2014 10:25 am

      We agree. By putting so much effort into the creation of a parallel system (here in Ontario) we dilute our energy and focus on a more effective solution which is to push for an Ontario organic regulation.

  21. December 5, 2014 3:15 am

    Either of these options might work for us.

    Cost may be an issue. We would be willing to pay a percentage of cash gross, but as a co-op, we include farm products we consume as income on our books. So it wouldn’t work for us to pay a percentage of gross if it includes non-cash work-trade.

    A bigger concern is that we recycle our personal waste. Unlike using commercial sewage sludge, we know what goes into (and what comes out of) our bodies! We eat primarily organic food, and so the, uhm, “organic fertilizer” we produce should be organic, as well. And people who are on antibiotics, birth-control pills, etc. are asked not to “contribute.”

    However, I’ve been told that humanure of any sort disqualifies us from organic certification.

    Closing the nutrient cycle is non-negotiable, even if everything else were dead simple. It’s a matter of principle.

    • Stuart McMillan permalink
      December 11, 2014 1:12 am

      I inspected a certified organic operation that composted their humanure. Their solution was to use it on areas they never planned to certify, such as their fruit trees for personal consumption or annual flower beds. Really use of humanure on vegetables for retail sale is a pretty questionable practice and beyond the organic standards may land a super sustainable farmer in hot water given current approaches to food safety.

      You are correct though that based on most certifyiers interpretations that humanure is viewed as sewage sludge … even though the reason sewage sludge is prohibited is not because of pathogens but due to all the heavy metals and nasty stuff coming from the combined sewage systems of urban areas.

  22. December 5, 2014 9:36 am

    Since I am not certified, but I understand the standards & have training, we are basically operating with the “Organic Affidavit” model, but it’s not ideal.

    I am most interested in the “Certified Local Organic” option presented, as producers in my area of NL have discussed this idea over the last few years..
    I understand a big pitfall with peer review is the awkwardness of inspecting a friend/neighbors/community members business, and have to report on something sub-standard..
    Yet, how can we make an “efficient” (cost of fees, time to do paperwork) certification system? We want organic farmers have recognition for their work and trace their products, but the accountability for farmers on small holdings and selling direct to customers, seeing their faces and knowing their names, is far different than the needs of certification for export & grocery store / wholesale, different again than the needs of organic processors..

    There is an element of professionalization necessary for export & processing on a larger scale; but this shouldn’t be at the expense of small scale local production.

    Its also a miss in ‘organic’ that there is not much about the health of workers/farm labourers, for distance of transport, for the amount of plastic garbage created.. can we really have organic lettuce in Newfoundland from California, which is grown on a monocrop scale, harvested by migrant workers in questionable conditions, and shipped across the continent? A sprig of organic rosemary in plastic from Israel?

    Its also tangly when cert bodies are for profit — maybe there is a role for provincial governments to take as a nonprofit certifier. In Atlantic canada there is a nonprofit certifier, ACO, which is volunteer and cooperatively run.

  23. December 5, 2014 1:15 pm

    Where to start? We have been certified for more than 10 years, we feel that it is the “right” thing to do, but really, we have over 250 customers, mostly retail operations, only 1 has asked for our paperwork. That bothers me, it tells me that retailers don’t care and they are only after making a buck or two on re-selling my product. More and more my product has to be “perfect” or else the retailer won’t take it. What is the reason for the certification? So the end customer knows the product is certified. I don’t think the end customer cares. This forum should be for customers, not farmers. Why don’t we do what the customers want us to? Isn’t that why we are all in this crazy business to begin with?
    I also think the certifying bodies are having a tough time finding an efficient way of getting all of us certified. We have been doing the same farming for 13 years, but every inspection is such a hassle that we really don’t have time for. I keep thinking, one of these days I’ll get enough staff and one of the staff should be able to take on all that is required for certification, but that staff member hasn’t shown up yet, and I like so many other farmers out there are wearing all the different hats that come with running the farm. But when it comes down to it, there is still only one hat and one head at any given time. The certifying bodies have made a bunch of round circles in which all farm information should fit, but it seems many of us are doing niche products and are growing many different crops, there seems to be many producers trying to fit their square peg of what they are doing into those round circles. One thing that might help is a real time inspection, ie here is the current crop and here are the inputs and here is what we should get and here is where it should be going. I find to pull up the records of last year crops, try to remember what happened if something is missing, it should all be there for food safety reasons, but most of us in fresh market production really don’t care what happened a year ago, we are busy with current matters.

  24. Rob Campbell permalink
    December 5, 2014 7:09 pm

    Thinking of subsidies, it is a pity that the PMRA (Pesticide Management Regulatory Authority) is under Health Canada and not associated with the CFIA (which gives force of law to the organic standards). If they were linked then fees and fines for pesticides could be used to subsidize organic administration costs.

    Some replies above argue that this is an Ontario issue. While I think this affects all provinces that have not opted out of CFIA regulation, can anyone justify the costs versus benefits for Ontario to opt-out of CFIA regulation and try to solve this issue (and maybe others) with parallel regulation? Could/should a solution be piloted in Ontario before rolling out across the country?

    I’m just trying to open up discussion on implementation options — please add your thoughts of different ways organic certification could be done or funded.

  25. Linda Moore permalink
    December 7, 2014 10:11 pm

    As a consumer, I think that the self-declaration and peer reviewed categories will only serve to further confuse and alienate potential consumers who remain skeptical regarding the organic label. I know my local producers. Some are certified. Some are not. But, I have taken the initiative to visit their farms to learn about their agricultural practices. Keeping it simple for the general public may garner more supporters and consumers of organic agricultural producers.

  26. December 8, 2014 4:59 pm

    My experience with the organic certification process has been mostly negative. I farmed 1/2 acre this year (1 acre next year) on an incubator farm that was certified and therefore I had to follow the requirements. As a very small scale artisanal producer I am interested in delivering both high quality and significant variety to my small customer base while maintaining the highest possible ethical standards. To be required to keep track of all 110 different varieties I planted from seed to sale was an absurdity. Many of the other farmers on this incubator also struggled with the significant increase in workload that this bureaucratic exercise in box checking and hoop jumping entailed. Unless some version of the self-declaration model is adopted very soon I will be pushing to have the incubator de-certify, nor will I be seeking certification post-incubator.

    As mentioned in some of the comments above, customers should be skeptical about the present version of the ‘certified organic’ label. For the most part it is just another avenue for large industrial producers (aka mono-croppers, aka grotesque abominations) to boost revenues. While this may not have been the original intent it is certainly the present reality, and is but one of many unfortunate examples of regulatory capture. I think that those in this comment stream worried that the affidavit model would somehow lead to the undermining of public confidence in the present model should take a bigger picture view, one that looks at the incentives to cheat the system by producers at different levels of production. At the one extreme there are the small producers like myself and slightly larger. I doubt anyone would suggest that many in this group are in the game to get rich, or that they would think that pouring poison on food or destroying soil to increase yield was an ethical or viable way to proceed. As it stands, certification provides little, if any, financial benefit to this group when its labour and opportunity costs are assigned even very modest values. These are not the folks that one should be concerned about when questions of compliance are raised. These are not the droids you are looking for. At the other end of the spectrum are of course the “Big Guys”. They have every incentive to cheat as the price difference, and therefore potential revenue, between conventional and “organic” is very significant at high volumes. Does anyone in this forum have any faith that inspectors in many impoverished (or not) countries would be adverse to having their palms greased in exchange for a clean bill of health or that industrial producers are so gosh-darn ethical that they would rather lose millions to an unforeseen disease outbreak than give a covert hose-down? There are no ethics at that level, only money and fiduciary duty to shareholders. As an ex-enviro tech who has had the misfortune to have worked at the feet of industry I have seen it with my own eyes and hear it with my own ears numerous times. Like Tech-Cominco dumping holding tanks of heavy metal laced effluent into the Columbia because it was much cheaper to pay the fine than to truck it away (Luckily the study that we did on the effect of these practices on endangered juvenile White Sturgeon concluded that there was no effect. Whew! Study paid for by Tech-C, BTW). Or logging companies pouring hundreds of liters of used hydraulic and lubricating fluid from machinery onto the cut block ’cause, like, what else are you gonna to do with it in the middle of nowhere, eh? With these types of well-documented practices as a backdrop how on earth can an multinational industrial agribusiness employing slave labour qualify for a certified organic label and if they do then what exactly is that label really worth? To me, nothing. Where is the integrity?

    If healthy food is actually a desirable situation then let it be seen as a public good and have its production be rewarded as such. If it is deemed that we must use bureaucratic methods to ensure this then immediately disqualify any production from any jurisdiction that cannot be directly inspected and pay individual producers government-level mid-management wages to do the paperwork. I’ll reluctantly fill out your forms and keep your records for $40/hr. Or better yet I’ll hire someone to do it at a reasonable wage. Seeing as the smallest producers carry the highest relative administrative burdens under the current system I think the aforementioned compensation structure is a fair and equitable solution and would provide an appropriate amount of incentive to those that would otherwise sensibly eschew such a byzantine approach. Raise the money through a small (or large) tax on the very poisons that are doing all the damage.

    • Rob Campbell permalink
      January 3, 2015 8:47 am

      I think your arguments raise two good points. First, maybe certifying bodies and/or governments should give more scrutiny to the organizations that have financial incentive to bend the rules (and if they already do then prove it and publicize it). Second, providing a stipend to small producers is a funding alternative to reducing certification costs.

      As another small producer, I agree with your sentiment about big organic, but not your argument. If you believe big-anything will always cheat then there is no point to any label, certification or regulation. Period. It is the guilt-by-association fallacious argument and as such is a non-starter.

      I believe you are right that small producers don’t have the resources or motivation to cheat the system; I believe their transgressions tend to be more from ignorance than intent. Consumers, animals and the land can still get sick from their transgressions. Any regulation should focus on *doing* things “right” (for some consensual definition of “right”). The protection is only effective if it affects outcomes. Thinking “right thoughts” is neither necessary nor sufficient to get “right” outcomes.

  27. Kate Storey permalink
    December 8, 2014 5:37 pm

    The integrity of organics is under constant attack from the pesticide pushers and our certification system is the one thing which builds credibility for organics. We can not afford to weaken it. I think that we should be looking for a way to bring the cost of certification down by finding ways to subsidize the cost of organic certifying bodies. If government won’t subsidize organic certification, maybe there is a benefactor out there who will.

  28. December 8, 2014 11:26 pm

    I am hesitant towards self certification – especially if the focus is organic for the reason of confusing the public on the organic standard. But the problem still exists for small growers, how can they access something like the organic label that communicates that message to the public easily?

    What about going beyond the organic standard minimums. This is something small growers can do and do do often. What about a focus on nutrient density? Make clean ecological production a given and work towards defining small accomplished growers as ones that go beyond the standard.

    There are additional values a strong smaller grower brings: hand tended, extreme biological diversity, artisanal qualities, reduced erosion & increased organic matter with bio-intensive methods, direct community engagement. Maybe there is space for SMALL farms to promote the “un-seen” value customers get when they support small farms.

    I think in any self imposed certification system is dangerous as it’s integrity could be very easily compromised. Certified Naturally Grown has a whole system for farmer to farmer certification. Whether self or peer certified, the work needed to clearly communicate the message to the public will need to be well coordinated and take a long term approach.

    Keep the good conversation going!

  29. Stuart McMillan permalink
    December 11, 2014 1:21 am

    I wanted to send my comments (plus others) directly to OFC and the Technical Review Committee, but was informed posting on the blog was the required method of communication. I have already commented about the challenge that these proposals will not apply to 40% of the organic producers in Canada

    I call for the rejection of these proposals as a very small, diverse, certified organic vegetable production farm which only sells intra-provincially. We chose to certify before the Province of Manitoba ratified its intra-provincial regulation. Not because the change was coming, but because we knew it was critical to providing buyers, and ultimately eaters, confidence that we were following the full practices of the Canadian Organic Regulation.

    The pledge model is a joke. I can put it no other way. To simply ask growers to pledge to follow the organic standards is ridiculous, this is not better than what is already happening at farmers markets where there is no intra-provincial regulation in place. “Yeah I follow the standards, but it is too much work and cost to maintain the certification.” When in fact the person making the statement has never once read the standard, does not understand what the requirements are, does not keep up to date with changes of the standards and had never once has had to prove they follow the standards, never once had an unannounced inspection. People will state any number of things if they think it will make a sale and if it will allow them to charge a premium. There is no mechanism for enforcement, compliance and addressing of complaints. The pledge must be rejected without further consideration.

    Peer reviewed systems have more credibility. There are still challenges with this system. As pointed out, until there is large buy in the travel distances by peers may be great. The ability and competence of the person assessing their peers will vary immensely compared to a certified organic inspector who is required to take initial training, on-going professional development, attend webinars, etc. Additionally, to open your records and books to your peers is also opening your books and records to your competitors. This model will likely be fraught with people not providing full disclosure of practices and markets. Organic certification works because the inspector has no involvement in the sector, is independent, and has confidentiality agreements signed. Also the inspection of these farms will all occur at the time when the farmers themselves are busy doing the same things, there may be scheduling challenges compared to a professional who is only inspecting organic farms. It is suggested that the cost be based on gross sales. If you make costs based on gross sales of organic product you will get creative record keeping. This is a well established reality looking at other agriculture programs. The ways this happens are myriad – the organic crop sale is reported as being sold as conventional, those organic cash sales at market were not recorded, and on and on.

    If a peer reviewed system is the solution, then let growers who choose not to certify use one of the existing peer reviewed systems, that do not use the organic term and do not confuse consumers. We should not change from the current requirement “Products that make an “organic” claim must be certified by a Certification Body that has been accredited, based upon the recommendation of a CFIA designated Conformity Verification Body.”
    As it stands the current certification model already suits small growers such as my family.
    • It is affordable and reasonable in cost and record keeping requirements.
    • It provides integrity and consumer assurance.
    • It adapts to the changes of the COR regulations and on-going science of organic agriculture.
    • In ensures uniform application of the standards. Small to large, we all play by the same rules.

    • December 11, 2014 9:40 am

      Well said Stuart! I agree 100%

      • January 24, 2015 5:38 pm

        Stuart. you said it all . The present system keeps us honest. there are too many organic claims that take shortcuts already.

  30. Ken Laing permalink
    December 11, 2014 9:37 am

    Our farm was certified for 17 years when we were producing crops sold through distributors and certification was required. Once we developed our present CSA and all our farm’s production is sold through the CSA we stopped certifying. All our members pick up at the farm and have the opportunity to see the farm and talk to us directly. We had very few inquiries when we stopped certifying.
    I think that what ever we can do to increase the “culture” of organic production is good. The peer reviewed model sounds exactly like what OCIA started as.That disappeared as certifiers were regulated. The affidavit[pledge] model answers many of the issues farmers have with high cost of regular certification. It is the option I would like to see implemented It would still have a cost if random or compliant based inspections are built in. The pledge model can be used to educate farmers if they are required to read and understand the standards. No amount of certification and regulation can make everybody honest.

  31. January 9, 2015 4:29 pm

    We operate a small mixed veg and fruit operation going into our 3rd year of non-certified organic production, and we fully follow the standards. The only reason we haven’t certified yet is that we are growing on rented land and we don’t know how long we’ll be where we are. In fact we are moving the whole operation to a new farm that is certified organic for 2015. Once we do buy a farm (fingers crossed for 2015) we will begin the certification process.

    Although I don’t think the cost(both $ and paperwork) of certifying is outrageous it would be nice to see a tax credit or something for those farms that do go ahead with certification, and hopefully in the future being certified won’t require you to pay for it. Adding different tiers or names will only confuse eaters, and invalidate the whole “certified organic” movement as it would become a lot more grey.

    I wish the “self-certified” method were possible but I can think of a handful of producers that currently don’t follow the standards who claim to, and they would be keen to self-certify.

  32. Bousfield's Apples and Cider permalink
    January 21, 2015 11:38 pm

    We were certified as Organic for a few years but begrudgingly watched the costs increase every year as the corporate monster, the `certifying body’, required more feeding.

    We cancelled the certification.

    We’ve remained `organic’ as far as the practices go, and our customers know, and we’re advocates of the peer-reviewed alternative this website proposes but some of the regulations need adjusting. For example, why should we have to wait till a deficiency of a trace mineral is proven by an expensive soil or leaf analysis before adding a touch of that mineral? Isn’t it too late by then? What’s wrong with an organic farmer mineralizing their crop regularily? If the soil pH is too high for maximum bioavailability, why can’t an organic farmer use a foliar spray to supply vital minerals without the burden of lab tests? The demand for a soil or leaf analysis to prove the mineral deficiency is an economic hurdle for a small-scale farmer. Is this regulation another way to make `Organic’ certification prohibitively expen$ive?

  33. Heather King permalink
    January 27, 2015 12:32 am

    I was certified organic but had to give up certification due to cost. I feel that the cost needs to be addressed. We are in downhill spiral where the costs of certification keep going up due in part to fewer farmers certifing and the costs incurred by the certifying party I don’t think a three tier approach would help the industry and the uninspected may get behind on what is acceptable as things change over time. How can the expenses be lowered? I feel that is the question

    • January 27, 2015 9:15 am

      It would be interesting to hear from people involved in the BC discussions regarding that province’s possible ways of supporting small farms under the new regulation– particularly for those selling products strictly within the province. It seems that this a specific way the provincial ministries of agriculture can provide support to small scale organic farms.

  34. William Robinson permalink
    February 28, 2015 12:04 am

    Iike up coming news.

  35. March 4, 2015 7:22 pm

    The idea of peer review is great. go for it. local low cost and honest.

  36. Susan Linkletter permalink
    June 2, 2015 9:22 pm

    OCIA lets farmers certify as a group as long as no more than one farmer in the group makes more than 10,000 dollars. Seems to me that this is the best way for a small farmer to certify their product as long as they can find other producers to work with them. A group of four farmers sharing the cost of one application for certification would amount to a certification cost of about $200 per farmer, which is affordable for most.

  37. Franck permalink
    December 3, 2016 11:07 pm

    Guys. It’s really simple. The issue is making the change nation wide and implementing a law that would have producers who use herbicides, fungicides, pesticides, label their products. We got this backwards right now. If a producer wants to pollute the environment and leach cides into the oceans and are okay with this, then let the people know on your labels. They will make the choice for themselves. Now if only politicians would even start pretending to care about the agricultural system in Canada.

  38. March 11, 2017 11:53 am

    Before WW11 all farming was organic, after WW11 the discovery of synthetic nitrogen from the Haber-Busch process we started farming “conventional”. How long were we farming before WW11? Thousands of years.

    I could go on a long spiel about the pesticides, herbicides and fungicides that are now required mainly because of the farming models we have adopted, but I won;t do that.

    Now today, if someone wants to farm what I would say as “conventional” (the way we did it for thousands of years) we need to certify, spend money that needs to be recovered etc…

    I myself am a small organic market farmer, not certified and never will be for the simple reason that no matter what the cost, it is unfair to organic farmers, it raises prices especially for the small guy like me. We should be looking at ways to lower the cost of food, make it more accessible to the less fortunate rather than adding extra costs, paperwork etc…

    If the brand is being hurt, that’s not because of the small guy like me, that’s because of the short-sightedness of our governments.


  1. - Group Looking For Ways To Certify Small-Scale Organic Farms
  2. Sustainable Agriculture News from ATTRA
  3. To Certify or Not To Certify: The perspective of small-scale organic farmers | Kootenay Food
  4. To Certify or Not To Certify: The perspective of small-scale organic farmers – Kootenay Food

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