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RG-1 Regulatory Guidance:
Chapter 4 - Labelling and guarantees

4.12 Permissible claims policy for livestock feed

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Scope

This document sets out guidance on permissible claims that may be used on livestock feed labels without the need for product registration. Once published, this policy will take effect immediately.

Current state

All information on livestock feed labels, including words, pictures, and logos, contribute to the overall impression created about a feed product. It is the responsibility of the feed manufacturer or seller to comply with the labelling, and other regulatory requirements of the Feeds Act and regulations.

A claim is considered to be any representation which states, suggests, or implies that a mixed feed or single ingredient feed has particular characteristics relating to its origin, nutritional properties, nature, purpose, production, processing, quality or composition, or any characteristic that relates to animal productivity, animal health, food characteristics, food quality or the environment.

Benefits

This policy will allow certain claims (pre-approved or permissible claims) that are on the permissible claims list to be added to livestock feed labels without the need for mandatory product registration by the Canadian Food Inspection Agency (CFIA). The benefits and anticipated outcomes for permissible claims include:

Permissible claims guidance

Introduction of permissible claims

To provide greater flexibility, the CFIA has developed a new policy to allow certain claims to appear on livestock feed labels without requiring registration of the feed. A list of permissible claims (pre-approved claims) can be found in Appendix 1. Claims that are considered suitable for this policy:

In all cases, claims must be accurate and truthful.

Permissible claims list

The permissible claims list consists of pre-approved claims that may be used on livestock feed labels and the conditions that need to be met prior to using that claim. Appendix 1 is divided into 4 tables. Tables 1 to 3 contain both general and method of production claims. Table 4 contains statements related to endorsement, marketing or promotional information about the company or business practices rather than the feed itself.

Feeds that are exempt from registration will be able to include claims set out in the permissible claims list without requiring product registration if the feed meets the conditions as listed for that claim.

When using a claim from the permissible claims list from Tables 1 to 3 of Appendix 1, the regulated party:

Regulated parties must have information available to substantiate the claim in the event that the CFIA requests it.

Claims that do not meet all of the above requirements would be considered out of compliance with the permissible claims policy.

If a regulated party wishes to use a claim that is not on the list, the feed will require registration and information supporting that claim must be submitted as part of the application.

Feeds that require registration for reasons other than a claim will still require product registration even if they are labelled with a permissible claim.

Labelling requirements when using a permissible claim

Feed claims may be found as a statement on a label or as part of the feed name. If a mixed feed has a specialty purpose mentioned in the feed name or stated in another part of the livestock feed label, this would be considered a claim. For example, a label states that, either as part of the feed name or somewhere else on the label, a mixed feed is an odour control agent or is a mould inhibitor. Since these claims are not included on the permissible claims list, the mixed feed would require registration.

All claims on livestock feed labels must be accurate, truthful, and must not mislead or deceive the purchaser of the feed.

Compliance and enforcement

During compliance verification activities carried out by the CFIA, regulated parties may be required to provide information to substantiate or support the permissible claim. This could be:

All documents used to substantiate a permissible claim must be made available to the CFIA upon request. Enforcement actions may be taken and follow up may be required if there is a reason to question the truthfulness of the claim or statement.

For method of production claims, acceptable ways to substantiate the claim may include:

For some of the method of production claims (for example, raised without the use of antibiotics claim), sequencing and flushing documentation is an example of documentation that substantiates these particular claims and may be requested by a CFIA inspector.

For endorsements or promotional or marketing statements, acceptable ways to substantiate these statements may include:

With regards to a feed label having a logo of a third party certification program (for example, FeedAssure®, HACCP, GMP+, Non-GMO Project Verified, etc.), the CFIA would verify that the company is enrolled in or part of the program for that particular logo, but the CFIA would not verify that they meet the standards or criteria of that program. As part of routine inspection activities, the CFIA could verify that the company is in good standing with that program.

For the endorsement, promotional or marketing statements on feed labels (for example, logos of third party certification programs, etc.), information explaining what those logos and statements mean would need to be publically available so customers would be able to understand the statements being made.

Even though, the Non-GMO Project Verified logo is one of the logos that the CFIA would allow on a feed label (provided certain conditions are met), label claims or statements respecting novel traits or genetic modification such as genetically modified organism free, would not be considered acceptable under this policy.

Process for adding or removing permissible claims to the label of a registered livestock feed

The addition or removal of permissible claims to a label of a registered livestock feed is considered an administrative amendment. The addition of permissible claims to a label of a registered livestock feed is allowed, provided that all of the conditions for that permissible claim have been met. An application for an administrative amendment to the feed registration, along with copies of the updated label and application fees would be required. If this is submitted at the time of renewal, the administrative amendment fees are in addition to the applicable renewal fees for the livestock feed product. Please refer to CFIA's Fees Notice for current fee amounts.

If a regulatory party requests market access documents (for example, certificates of free sale) from the Animal Feed and Veterinary Biologics Division, they must provide the most recent label for their livestock feed product. Any updates to the registered livestock feed label must be addressed through an application form, labels and applicable fees, before such documents are issued by the CFIA.

Additional information on the administrative requirements for pre-market assessment and product registration for livestock feed can be found in Chapter 1 of RG-1.

Next steps

The CFIA is working on changes to the Feeds Regulations which would propose to introduce the permissible claims approach into regulation through the use of incorporation by reference (IbR). A proposed Tables of Permissible Claims on Feed Labels would be incorporated into the regulations and would allow claims to be made for livestock feeds similar to how it is described in this policy.

If you have any comments, questions or feedback on this policy, please contact the Animal Feed and Veterinary Biologics Division.

Appendix 1 : Permissible claims list

Permissible claims related to the quality and content of the feed

Tables 1 to 3 outline the permissible claims currently allowed for feeds. In the approved claim column, options for wording of the claim are listed. Regulated parties may choose which of these approved claims is suitable for their livestock feed, if applicable. The optional claim column provides options for the wording of other claims that may be added. Feed products making a permissible claim must use the approved claim, but may also include an optional claim. The optional claim (for example, raised without antibiotics (RWA)) can be part of the product name on the feed label and an asterisk can be used to link to the approved claim on the label. All of the information found in conditions for the feed column and conditions for the label column must be met to be able to use the permissible claim.

Table 1: Claims respecting organic
Approved claim Optional claim Conditions – feed Conditions – label
  • Organic
  • Contains X percent organic ingredients
  • Canada Organic logo
  • N/A
  • The feed must meet all of the conditions of Part 13 of the Safe Food for Canadians Regulations. Refer to Organic products
  • The label must meet the conditions in Part 13 of the Safe Food for Canadians Regulations. Refer to Organic products
Table 2: Claims respecting method of production
Approved claim Optional claim Feed conditions Label conditions
  • This feed is suitable for use as part of the raised without the use of antibiotics program
  • Raised without the use of antibiotics
  • RWA
  • The label may only contain claims as worded in the "Approved claim" column
  • The claims in the "Optional claim" column may only be added to the label if the "Approved claim" also appears on the label
  • "Free from" claims are not allowed
  • This feed is suitable for use as part of the raised without the use of added hormones program
  • Raised without the use of added hormones
  • The label may only contain claims as worded in the "Approved claim" column
  • The claims in the "Optional claim" column may only be added to the label if the "Approved claim" also appears on the label
  • "Free from" claims are not allowed
  • This feed is suitable for use as part of the raised without animal products, animal by-products, animal fat, animal meal, and/or bone meal programTable Note a
  • "Raised without" or "Fed no" and
    • animal products
    • animal by-products
    • animal fat
    • animal meal, and/or
    • bone meal
  • The label may only contain claims as worded in the "Approved claim" column
  • The claims in the "Optional claim" column may only be added to the label if the "Approved claim" also appears on the label.
  • "Free from" claims are not allowed
  • Note that the term animal includes insects, fish and shellfish
  • This feed is suitable for use as part of the raised without the use of medically important antimicrobials (MIAs) program
  • Raised without the use of MIAs
  • The label may only contain claims as worded in the "Approved claim" column
  • The claims in the "Optional claim" column may only be added to the label if the "Approved claim" also appears on the label
  • "Free from" claims are not allowed
  • This feed is suitable for use as part of the grain fed program
  • Grain fed
  • The feed must be made in a manner that is consistent with the CFIA Food Program's policy on method of production claims
  • This claim can only be made on complete feeds, and must meet the minimum percentages of grains or grain by-products allowed in complete feeds for certain livestock species outlined in the policy
  • The label may only contain claims as worded in the "Approved claim" column
  • The claims in the "Optional claim" column may only be added to the label if the "Approved claim" also appears on the label
  • "Free from" claims are not allowed
Table 3: Claims respecting the absence of ingredients in the feed
Approved claim Optional claim Feed conditions Label conditions
  • Contains no animal products, animal by-products, animal fat, animal meal, and/or bone mealTable Note b
  • All vegetable
  • AV
  • The feed must be made in a manner that is consistent with the CFIA Food Program's policy on method of production claims. Refer to this policy for any exceptions
  • No single ingredient feed of animal origin is to be used in the manufacture of livestock feed when claiming the livestock feed does not contain that single ingredient feed of animal origin
  • The claims in the "Optional claim" column may only be added to the label if the "Approved claim" also appears on the label
  • "Free from" claims are not allowed
  • Note that the term animal includes insects, fish and shellfish
  • Contains no added medications
  • N/A
  • The feed must be made in a manner that is consistent with the CFIA Food Program's policy on method of production claims
  • No added medications are to be used in the manufacture of livestock feed when claiming the livestock feed contains no added medications
  • "Free from" claims are not allowed
  • Contains no added antibiotics
  • N/A
  • The feed must be made in a manner that is consistent with the CFIA Food Program's policy on method of production claims
  • No added antibiotics are to be used in the manufacture of livestock feed when claiming the livestock feed contains no added antibiotics
  • "Free from" claims are not allowed
  • Contains no added medically important antimicrobials (MIAs)
  • N/A
  • The feed must be made in a manner that is consistent with the CFIA Food Program's policy on method of production claims
  • No added MIAs are to be used in the manufacture of livestock feed when claiming the livestock feed contains no added MIAs
  • "Free from" claims are not allowed

Permissible statements and logos related to national or international industry certifications, or endorsements or marketing and promotional practices about the company

This table is not exhaustive and provides examples of what statements, logos or information would be acceptable on labels for mixed feeds or single ingredient feeds. Note that the following acceptable statements, logos and other information can appear on accompanying documentation as well as on the feed labels.

Table 4: Permissible statements and logos
Type of statement Acceptable statements, logos and information allowed on feed labels

Statements highlighting national or international certifications

  • FeedAssure®
  • GMP + FRA certification
  • ISO certification
  • GMP + FSA certification
  • GMP+ certified
  • HACCP certification
  • Safe Feed/Safe Food Certification Program
  • Non-GMO Project Verified

Statements highlighting the company's endorsements

  • Official sponsor of XX
  • Official feed of the XX Olympic games
  • Statement, logo or information about a company promoting an event or conference that they are hosting

Statements highlighting the company's marketing or promotional practices

  • Company X donates a portion of proceeds from each sale to animal welfare organizations
  • Information on the history of the company
  • For every bag sold we'll donate X amount to X charity
  • Made in Canada/proudly made in Canada
  • Made from imported and domestic feed ingredients
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