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CanadaGAP Certification protects the entire Canadian fresh produce supply chain. Like most GFSI benchmarked certifications, CanadaGAP aims to update their standards every 2-3 years which has resulted in the recent release of version 11. Audits on or after 4/1/26 will be based on the Version 11 requirements and adhere to a more detailed and specific framework for the safe production, packing, and storage of fresh fruits and vegetables.
In 2026, Kiwa ASI merged with TSLC to combine Canadian regional expertise with broader resources and global technical expertise. With headquarters in Ontario and Vancouver, Kiwa ASI Canada (formerly TSLC) has auditors and staff all over the country, delivering expanded services, consistency, and support across any CanadaGAP certification journey.
In this article, we will outline 8 key changes in the transition from Version 10 to Version 11. Our goal is to simplify these updates and provide a solid place to start for Canadian produce operations, large and small.
1. New definitions & terminology
For clarification purposes and to account for other changes in the manuals, there are new definitions added to the glossary for 'laundered’ and ‘lubrication water.’ Laundered means to be cleaned in a way that ensures the items will not be contaminated. The cleaning should be managed under the operation's control.
The term ‘lubrication water’ was previously combined with 'final rinse water' but now the term stands on its own. The definition for Lubrication Water, as per the CanadaGAP glossary is ‘Water used for the lubrication of product (e.g., potatoes) before packing.’
The definition for 'market product' was also refined to be: ‘produce that is in market ready packaging. It may be packed in the production site or packed/repacked in the packinghouse. This would also include produce ready for market, but that is not sold/distributed in market ready packaging materials (e.g., bundled leeks on pallets going to food service, retail, customer, repacking, etc.)’ to better reflect that it is the use/destination of the product that makes it market product, not just the type of packaging materials it is in.
Lastly, the terminology in Section 1: Commodity Starter Products was revised to mirror the terminology used by the CFIA. This allows us to differentiate Plants with Novel Traits (PNTs) from Genetically Modified (GM) plants, two terms that should not be used interchangeably.
2. Letters of Assurance
One change that is specific to the Greenhouse Manual is in the Premises section (2.1) regarding letters of assurance. Sites have always had to provide a letter of assurance for their growing medium, but Version 11 clarifies that greenhouse operations are required to secure one letter of assurance per supplier, per season.
3. Sanitation guidance
Additional guidance for cleaning equipment is included in the Equipment section (8.2). Cloths used to wipe products must be clean, meaning ‘new or laundered by the operation’ and replaced daily. This ensures the cloth will not be a source of contamination.
4. Packaging materials update
In Section 17 you’ll see that the requirements for ‘Packaging Materials’ does in fact apply to wholesaling operations. Wholesalers must follow the requirements of the standard for packaging accessories like shrink wrap, pallet wrap, labels, etc.
We also learn in sub-section 17.2 that pumpkins can now be placed directly on the ground whereas they previously needed to stay off the ground. You may be wondering...how would the pumpkins react to this news? Our best guess is- they'd be floored.
5. Clarified Mock Recall requirements
Additional wording is included in Deviations and Crisis Management sub-section 23.3 to clarify this requirement applies to an operation’s entire traceability system. The person responsible is expected to conduct a mock recall annually to test their systems with the current season’s product, and if there are multiple ways that the company tracks their product, the mock recall must reflect this.
During an informative webinar hosted by Food Safety Solutions Inc, Danni Kneeland shared her perspective on this change as an auditor and food safety trainer...
“In my opinion, this is the biggest change to be aware of. Testing your traceability systems has always been a requirement with mock recalls, but it wasn’t entirely clear until now that all traceability methods must be tested each year,” says Kneeland.
In the midst of an actual recall, the last thing you should be asking yourself is, “Can my recall program really do what it needs to do?”
6. More food safety culture resources for employees
Food Safety Culture is being emphasized and, in some cases scrutinized across the industry. No matter if you are pushing for or against this trending terminology, it’s a term that’s getting more attention and direct references in various standard requirements, including CanadaGAP Version 11.
Subsection 23.8 regarding food safety culture was realigned with GFSI requirements and emphasizes commitment must be made to maintain a strong food safety culture within the operation through communication, training, feedback and performance measurement. This responsibility will primarily fall on senior management, and they must commit to establishing direction, engaging personnel, and providing sufficient resources to maintain a positive food safety culture.
In Version 11 audits, auditors will be looking for evidence of a long-term commitment to sustaining and improving food safety, employee awareness and training, as well as sufficient resources for employees to access supporting food safety culture. Ensuring you have a strong internal audit system will become even more impactful to prepare for your upcoming certification audit.
7. Forms & Appendices updates
A single change was made to Canada GAP Form C: Additional requirements were added to mitigate possible risks associated with jewelry and other ‘personal effects’ in the production site (now aligning with requirements in Form D).
- Employees may wear rings as long as they will be covered with gloves; NO other jewelry is permitted.
- No false fingernails, eyelashes, or other such effects.
- No items in shirt pockets.
- No loose buttons on shirts or jackets.
An additional single change was made to Appendix Q: The list of MRL databases was updated for several countries based on feedback from Canada GAP program users and the availability of certain countries’ databases. This is helpful for any operation exporting products out of Canada.
8. Management manual changes
Several revisions and additions were also made to the CanadaGAP Program Management Manual for auditors and certification bodies, including an updated CAP Guide, audit duration clarification, requirements for CB calibration sessions, and more. For example, previously there was no minimum for multi-site certifications, but per the new Management Manual for Version 11, there must be at least eight locations with different addresses involved to qualify for multi-site certification.
One of the most noteworthy changes is a new clause (s) in section 3.3.5.4.1 Procedures which addresses a common issue CB’s face when a consultant is taking an overactive role during an audit. Third-party consultants are not responsible for carrying out food production activities within the operation or implementing food safety procedures on a day-to-day basis, therefore they are not allowed to answer questions from the auditor. Differentiating the consultant’s role from the primary on-site contact role can be tricky, but it’s a necessary line that operators must draw.
“It's not uncommon for the consultant to be the auditor’s main contact for the audit, so you can see where the difficulties can arise.” said Frank Schreurs, a 40-year food safety expert who played a key role in CanadaGAP’s early adoption.
“The prime contact person or management is responsible for food safety, so when they expect a consultant to do everything, they are merely punting the ball. Auditors will need to be more diligent in determining if that is the case, and they’ll need evidence that there is risk in that relationship, not just a feeling or opinion,” Schreurs added.
Schreurs was a founding member of the Canadian Horticultural Council (CHC) On-Farm Food Safety Committee, the group that created the CanadaGAP Program, and he led one of the first certification bodies to offer CanadaGAP. Today, he’s the Director of Agriculture & Feed Certification services at Kiwa ASI where he’s building upon TSLC’s glowing reputation as a go-to CanadaGAP certification body.
In addition to other changes to the management manual, the CanadaGAP Corrective Actions Request (CAR) form and the Corrective Action Plan (CAP) Guide were updated for Version 11. CanadaGAP’s CAP Guide is meant to walk sites through what they need to do to correct any non-conformances addressed during an audit. All corrective action documentation can be found on CanadaGAP’s website.
Conclusion: Next Steps to Getting CanadaGAP Certified
In summary, navigating the transition to CanadaGAP Version 11 requires a proactive approach to mastering new terminology, strengthening mock recall procedures, and defining clear boundaries for third-party consultants during the audit process. We strongly encourage all stakeholders to visit the CanadaGAP website to review the full "Summary of Changes" and stay informed on the latest communications.
And when you are ready to schedule your audit, remember that Kiwa ASI Canada is here to make the certification process EASY! By leveraging the expanded technical expertise now available through the Kiwa ASI and TSLC merger, Canadian operations can better prepare and ensure a seamless certification journey.
[Click here to read more about our CanadaGAP services & schedule your audit today!]
References:
https://www.canadagap.ca/audit-checklist/corrective-actions/
https://www.canadagap.ca/uploads/292/tools/22220/canadagap-cap-guide-version-3-0-2026-eng.pdf