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D-11-03: Phytosanitary Requirements to Prevent the Spread of Eriochloa villosa (Woolly Cup Grass) and Control Infestations in Canada

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Effective date: May 30, 2012


This Directive sets out the phytosanitary requirements to prevent the spread of woolly cup grass (Eriochloa villosa) in Canada. The purpose of these phytosanitary requirements is to prevent the spread of Eriochloa villosa to non-infested areas, to control existing infestations and, where feasible, eradicate them.

Table of Contents


This Directive will be reviewed every five (5) years or as necessary. For further information or clarification, please contact the Canadian Food Inspection Agency (CFIA).


Approved by:

Chief Plant Health Officer

Amendment Record

Amendments to this directive will be dated and distributed as outlined in the distribution below.

Distribution List

  1. Directive mail list (CFIA, other federal departments, United States Department of Agriculture, etc.)
  2. Provincial governments and non-governmental organizations (determined by Author)
  3. National industry organizations (determined by Author)
  4. CFIA website


Eriochloa villosa is a tall annual grass weed of the millet tribe, native to temperate Asia. Introduced into North America in the mid 1900s, it has become a weed that is a serious pest for large-scale farming. It occurs mainly in the northern corn belt of the United States (U.S.), in Illinois, Iowa, Minnesota, and Wisconsin where it is considered a weed of economic importance in corn and soybeans. In Canada, a localized infestation of woolly cup grass was detected for the first time in a field located in St-Hyacinthe in 2000. This population has survived winter conditions and has spread partially on the site. From 2007 to 2010, several new sites infested with the plant were found. It is therefore evident that Eriochloa villosa can survive and grow under Canadian climatic conditions, at least in plant hardiness zones 3 to 8, hence the possibility of a real threat to Canadian agriculture.

The primary economic impact of Eriochloa villosa is reduction of crop yields through competition as well as increased cost of weed control. Weed control is a standard component of any crop production system, but Eriochloa villosa is more difficult to control than many other annual grass weeds. Eriochloa villosa plants emerge earlier than those of other annual grasses and seeds germinate throughout the growing season. Commonly used pre-emergence herbicides do not provide adequate weed control. As such, more than one herbicide application is often necessary and later emerging plants may not be affected. The season-long germination capability can also limit the efficacy of other weed management methods such as weeding or mowing. Under ideal conditions, a single plant is capable of producing up to 164,000 seeds in a season. Most will germinate the following spring, while others will enter the soil's seed bank.

In the U.S., management of Eriochloa villosa has required the development of integrated programs that include cultural methods as well as increased cultivation and herbicide use. The additional herbicide applications alone can double the cost of chemicals needed in corn production, increasing the producer's overall production costs by about 18%.

The CFIA is responsible for establishing phytosanitary measures to prevent the entry and spread of regulated pests. Thus, under the Plant Protection Act, the CFIA may require the regulatory control measures presented in this document in relation to Eriochloa villosa infested sites in Canada.


In order to prevent the spread of Eriochloa villosa, the CFIA prohibits or restricts some activities (including movement) with regard to specific articles located in a regulated area. This Directive presents those conditions and restrictions. The CFIA is developing import requirements. Once these requirements are finalized, they will be referenced in the Directive.

The Directive describes:

  • the conditions for conducting certain activities in regulated areas and for using regulated articles;
  • the phytosanitary requirements applicable to crops contaminated with Eriochloa villosa;
  • the surveillance of regulated areas and detection survey of areas exposed to contamination; and
  • the process leading to the removal of regulatory control measures of regulated areas.

The requirements presented in this directive are intended for agricultural areas. However, control measures will be required if Eriochloa villosa is shown to spread in non-cultivated areas. The CFIA will determine these measures on a case-by-case basis.


  1. RMD-08-02: Pest Risk Management Document for Eriochloa villosa (Woolly Cup Grass). Plant Health and Biosecurity Directorate, Ottawa. 21 pages.
  2. ISPM No. 5, Glossary of Phytosanitary Terms, FAO, Rome. (updated annually)
  3. Wilson, C.E. 2002. Weed Risk Assessment - Eriochloa villosa (Thunb.) Kunth. PHBD Request No. 2001-42 (unpublished). Canadian Food Inspection Agency, Ottawa. 35 pages.
  4. D-95-26: Phytosanitary requirements for soil and related matter, and for items contaminated with soil and related matter. CFIA, Ottawa.
  5. PI-016: Requirements for inspecting articles for freedom from soil and debris.

Definitions, Abbreviations and Acronyms

Definitions for terms used in this directive can be found in the Plant Health Glossary of Terms.

1.0 Phytosanitary Measures

1.1 Legislative Authority

The Plant Protection Act, S.C. 1990, c. 22
The Plant Protection Regulations, SORS/95-212
Canadian Food Inspection Agency Fees Notice, Canada Gazette, Part I (as amended from time to time)
Agriculture and Agri-Food Administrative Monetary Penalties Act, S.C. 1995, c. 40
Agriculture and Agri-Food Administrative Monetary Penalties Regulations, SORS/2000-187
Seeds Act (R.S.C., 1985, c. S-8)
Seeds Regulations (C.R.C., c. 1400)

1.2 Fees

The CFIA is charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. For information regarding fees associated with imported product, please contact the Import Service Centre (ISC). Anyone requiring other information regarding fees may contact any local CFIA office or visit our Fees Notice Web Site.

1.3 Regulated Pests

Eriochloa villosa (Thunb.) Kunth. (woolly cup grass)

1.4 Regulated Articles

  • Any crops produced in a regulated area
  • Plants and plant parts (e.g. screenings and straw) from a regulated area
  • Soil and other related matter from a regulated area
  • Machinery, equipment and/or tools in or that have entered a regulated area

1.5 Regulated Areas

For the purposes of this Directive, "regulated area" means a perimeter in which Eriochloa villosa has been detected by the CFIA.

2.0 Specific Measures

2.1 Prohibitions and Restrictions

Any movement of Eriochloa villosa or regulated articles from a regulated area to a non-regulated area is prohibited without prior written authorization from the CFIA.

Under the Seeds Act, seed must be free of prohibited noxious weed seeds in order to be sold or imported into Canada. Under the Weed Seed Order, Eriochloa villosa is classified as a prohibited noxious weed seed.

2.2 Experimental Use

The use, handling, preservation and storage of grain of Eriochloa villosa are activities that present a risk to plant health, and as such these activities are prohibited. Activities may be permitted, however, under certain conditions and for specific purposes, including scientific research. The CFIA may require phytosanitary measures be in place, for example, to use, handle, preserve or store grain of Eriochloa villosa and to undertake field trials. Prior to obtaining seed of Eriochloa villosa or proceeding with research, written authorization and all required permits and certificates must be obtained from the CFIA. In addition, the experimental protocol must be approved by the CFIA prior to implementation.

2.3 Measures for Use of a Regulated Area

No crop coming from a regulated area can be used as seed.

Control of Eriochloa villosa within regulated areas will be ensured through issuance of a notice under the Plant Protection Regulations. The holder of the notice has the obligation to comply with the conditions described on his notice, which could include measures under this Directive. It is then the responsibility of the holder of the notice to ensure that the conditions of the notice be respected in the regulated area under their responsibility. It is also their responsibility to ensure that the conditions be brought to the attention of anyone who performs activities targeted by this Directive. This includes employees of the enterprise, as well as any third party, particularly any contract workers.

2.3.1 Quality Management System Manual

In order to cultivate land within a regulated area, the producer must prepare a Quality Management System Manual, (hereinafter referred to as the "Manual"). The purpose of this Manual is to document the practices that will limit the risk of spreading Eriochloa villosa outside the regulated area and increase the chances of eradication. The Manual will also allow the producer and the CFIA to follow up on the use of the regulated area and activities in respect of regulated articles.

The Manual must describe the measures which will be taken by the producer to contain and reduce the population of Eriochloa villosa at each stage of production. The Manual must also include records and documents to ensure traceability of regulated articles. Appendix 1 provides the elements to include in the Manual.

The Manual must be evaluated and approved by the CFIA prior to cultivating a regulated area. The producer must then follow the procedures established in the Manual. If the producer wishes to make a change to the Manual during the season, it must be approved by the CFIA, or a person authorized by the CFIA, before being implemented.

For non agricultural lands and lands that are not cultivated, the manual can take the form of a compliance agreement.

2.3.2 Inspection before Harvest

All regulated areas must be inspected by the CFIA, or a person authorized by the CFIA, before harvest. This inspection is intended to verify whether Eriochloa villosa is still present and when the phytosanitary measures applicable to this regulated area can be removed. Section 4 presents the criteria allowing removal of control measures. It is the responsibility of the producer to notify the CFIA at least five (5) days before harvesting, to ensure that the inspection takes place.

2.4 Cleaning and Movement Measures

2.4.1 Movement of Machinery, Equipment and Tools Outside of a Regulated Area

In this section, "machinery" means any type of truck, tractor, trailer or vehicle that moved in a regulated area.

The movement of regulated articles, including machinery, equipment and tools, from a regulated area to a non-regulated area is prohibited, unless a written authorization from the CFIA is obtained prior to movement and conditions set out in the authorization are complied with. The movement of unclean machinery represents a high risk of spreading Eriochloa villosa outside regulated areas. Soil and plant debris carried by the equipment may contain seeds of Eriochloa villosa. Similarly, there is a risk of contamination when using equipment and tools that have been in contact with Eriochloa villosa without prior cleaning. For these reasons, it is important to clean all equipment, tools and machinery to remove adhering plant debris and soil. Where possible, sites where Eriochloa villosa has been detected should be cultivated consecutively to prevent further contamination.

With the exception of the two circumstances noted below, the CFIA will authorize the movement of machinery, equipment or tools on the condition that soil and plant debris have been removed prior to leaving a regulated area. Appendix 4 of Inspection Procedure PI-016: Procedures for inspecting regulated articles for freedom from soil, plants, plant parts and related matter recommends good cleaning practices. The procedure also includes a checklist the producer can use to ensure the machinery has been properly cleaned.

The CFIA will accept incomplete cleaning of machinery where public roads are unavoidable in order to reach a regulated field. In this case, however, the CFIA requires that machinery be partially cleaned before leaving a regulated area. Partial cleaning involves removing coarse particles of soil and plant debris that can fall off during movement of the machinery.

Debris from cleaning must be collected and disposed of in accordance with Section 2.6 of this directive. The wash water and debris must never reach any ditches or waterways.

The producer must specify in the cleaning section of the Manual how machinery, equipment and other tools will be cleaned. Appendix 1 of this directive describes this requirement in greater detail.

The CFIA may also authorize machinery, equipment or tools to leave a regulated without having been completely cleaned, if it is moved to a site specified in the producer's quality manual, such as a garage, washing station, or silo, and if partial cleaning is conducted upon leaving the regulated area. Movement from these sites is permitted in order to return to the regulated area or to move to another site specified in the quality manual. All other movement must be in accordance with a written authorization issued by the CFIA.

The measures described in this section also apply to machinery, equipment and tools that are not owned or in the possession, care or control of the notice recipient. The producer must therefore ensure that the freedom from Eriochloa villosa requirement are known and adhered to by all persons moving in a regulated area. Cleaning must be conducted by the notice recipient or under his or her supervision. If the producer hires a custom operator to work in a regulated area, the CFIA must be informed in advance so that the holder of the notice can obtain written permission to this effect.

2.4.2 Movement of Crops Outside a Regulated Area

With the exception of circumstances noted below, a written authorization must be obtained from the CFIA before crops may be moved outside a regulated area.

The CFIA may authorize a crop to be moved outside a regulated area if destined for a site specified in the producer's quality manual, such as a silo or dryer. Movement of the crops from these sites is permitted in order to return to the regulated area or to move to another site specified in the quality manual. All other movement must be in accordance with a written authorization issued by the CFIA.

2.4.3 Movement of People Outside a Regulated Area

Any person leaving a regulated area must ensure that their clothing and footwear is cleaned. Soil adheres to footwear and it is common for seeds or plant debris to be found in the folds of pants, pockets, and footwear. For these reasons, it is recommended that coveralls and overshoes be worn and removed when leaving the regulated area and cleaned afterwards. When coveralls and overshoes are not worn, footwear must be cleaned in order to remove soil and plant debris that may have adhered and clothing should be shaken to remove plant debris.

2.4.4 Movement of Soil and Related Matter Outside a Regulated Area

Soil movement represent a high risk of spreading Eriochloa villosa. In addition to the requirements of Directive D-95-26 "Phytosanitary requirements for soil and related matter and for items contaminated with soil and related matter," soil from a regulated area can only be moved:

  • to another regulated area; or
  • to a CFIA recognized landfill site.

As per section 2.1, written consent must be obtained from the CFIA before soil and related matter can be moved outside a regulated area.

It should be noted that soil removed from a ditch separating a regulated and a non-regulated area will be considered as coming from the regulated area and must be treated as such.

2.4.5 Other Articles to Consider

Although some equipment may never leave a regulated area, it is important that equipment and tools be cleaned when they have been in contact with Eriochloa villosa. This applies, among other things, to storage equipment like silos and dryers containing crops from regulated areas. Once emptied, the equipment should be cleaned of crop residues to eliminate the risk of contaminating the next crop stored.

When a regulated article is sampled, the equipment used to sample it must be cleaned. The following are a few examples of regulated articles:

  • soil sample;
  • plant specimen for identification by a botanist;
  • crop sample.

Probes, spoons and other tools must be cleaned so as to dislodge soil and plant debris.

2.5 Eriochloa villosa Infested Crop Processing

In the case where a crop is infested with Eriochloa villosa, it must be processed in order to limit the spread.

An acceptable processing method must remove Eriochloa villosa seeds from the crop or result in devitalization. Any debris generated by such a process must be collected and destroyed so as to reduce the risk of Eriochloa villosa spreading. Section 2.6 outlines the disposal methods approved by the CFIA. Processing must be performed by a facility that has signed a compliance agreement with the CFIA. This agreement will consist of a description of the procedures that the facility must follow in order to limit the risk of spreading Eriochloa villosa. If the producer is responsible for processing of the commodity, the procedures must be documented in the Manual.

The following processes are recognized by the CFIA as being acceptable methods for removing Eriochloa villosa seed from a commodity or devitalizing it.

2.5.1 Screening

Screening consists of a mechanical sorting by size and density to separate the grain from its impurities. If it is done on the farm, it must be conducted in accordance with the procedures described in the Manual and a representative sample will be taken from the screened lot by the CFIA, or a person authorized by the CFIA, to ensure that the processing was effective. If the screening is performed by a processing facility, the compliance agreement will specify the sampling frequency.

2.5.2 Grinding and Milling

Grinding or milling consists of reducing grains to crumbs or powder. The milling must be fine enough so that no viable seed of Eriochloa villosa remains.

2.5.3 Pelleting, Micronizing and Extruding

Pelleting consists of converting milled ingredients into granules.

If the milling is not fine enough, pelleting will have to be performed at elevated temperatures in order to be recognized as an effective devitalization process by the CFIA.

Micronizing consists of exposing grains to infrared rays that increase their internal temperature and pressure to make certain otherwise non-degradable proteins available.

Extruding consists of forcing a product to pass through a small opening, or die, using pressure. This manufacturing process is performed at an elevated temperature and under strong pressure, and can be done dry or wet.

2.5.4 Other Processing

The CFIA may approve other processing methods on a case-by-case basis. An application describing the method's various parameters must be submitted to the CFIA for approval.

2.6 Disposal of material infested by Eriochloa villosa

The approved methods for disposing of debris or a product infested by Eriochloa villosa are as follows:

  • movement to an approved landfill
  • burial to a minimum depth of one metre
  • incineration
  • autoclaving
  • any CFIA-approved processing method that devitalizes the seed, such as milling, grinding, pelleting, micronizing and extruding, as described in Section 2.5.

The CFIA may approve other means of disposal on a case-by-case basis. An application describing the method's various parameters must be submitted to the CFIA for approval or, when disposed of on farm, the method must be documented in the producer's Manual.

Movement of regulated articles and/or contaminated material to a disposal site located outside a regulated area must be authorized in writing by the CFIA.

3.0 Detection Survey

Detection surveys will be conducted by the CFIA, or a person authorized by the CFIA, to determine if Eriochloa villosa is present in an area. Once Eriochloa villosa is officially detected, the area will be regulated and phytosanitary measures will apply.

4.0 Removal of Regulatory Control

Control measures relating to a regulated area will be removed when detection surveys have shown the absence of Eriochloa villosa for five (5) consecutive years.

5.0 Compliance and Exemptions

The CFIA will conduct inspections to verify that regulated articles comply with the measures described in this Directive. Any regulated article that contravenes the provisions of this directive will be considered non-compliant and will have to be disposed of in accordance with CFIA guidelines. Enforcement actions, such as Administrative Monetary Penalties, will be considered for all non-compliances.

6.0 Appendice

Appendix 1: Elements of a Quality Management System Manual

1. General

1.1 Administration

The Manual must indicate the name and address, the telephone and fax numbers, and the e-mail address of the establishment. All pages must be numbered. It is important to date the establishment's Manual. This section should also describe the farm's main activities.

1.2 Establishment Structure

The establishment must provide information on the role and responsibilities of employees whose work involves applying the various procedures relating to phytosanitary measures. When an operation is performed by a person other than an employee, that person's contact information and job description should be added in the relevant section.

1.3 List and Diagram of the Operating Sites (location)

A diagram or plan of the farm must be appended to the Manual. The plan must show all production areas, including leased land.

2. Cultivation Practices

2.1 Cultivation Management

The type of crop must be specified for every field in a regulated area. The Manual must also include a brief description of the cultural methods (e.g., culture on ridge, no-tillage seeding, conventional cultivation with tillage, etc.)

A record of cultural operations must be kept and made available. The record should include the dates of entry to the field and a description of the work done. A copy of this record must be appended to the Manual.

2.2 Phytosanitary Management of Regulated Areas

This section describes the integrated control plan that the producer intends to implement in order to reduce the Eriochloa villosa population. It must describe the planned crop rotations and a description of the selected control method, such as name and dose of the herbicide, mechanical tillage, field roguing, etc.

A record of field treatment, including date, type of treatment, product used and concentration, must be kept and made available. A copy of this record must be appended to the Manual.

2.3 Detection Inspections

The CFIA recommends that producers monitor their fields through visual inspection during the growth period in order to ensure early detection and rapid response for better control of Eriochloa villosa. The CFIA also recommends keeping a record of such inspections, including dates, observations and actions taken.

3. Harvest, Sale and Shipping

This section must describe how the establishment markets its commodities. The following information must be documented in a record:

  • date of the harvest;
  • quantity harvested;
  • storage location of the crop

The distribution of crops from regulated areas must be compiled so as to ensure traceability of sold lots. A copy of the record must be appended to the Manual.

4. Preventative Measures

This section is not mandatory, but highly recommended. It covers the good cultural practices that the producer intends to use to avoid contaminating areas where Eriochloa villosa has not yet been found. Among the recommended procedures are:

  • Use the same rotation for all areas where Eriochloa villosa has been found
  • Harvest areas where Eriochloa villosa has not yet been found first
  • Use dedicated equipment for regulated areas
  • Train staff to identify Eriochloa villosa at every stage of growth
  • Provide for visitor parking, where no farm machinery needs to circulate

5. Sampling

The establishment may occasionally have to collect samples of regulated articles, such as soil for analyses for the presence of seeds or suspicious plants for identification. In this case, this section should contain the sampling procedures and the contact information for the laboratory responsible for analyzing the sample.

6. Cleaning Measures

This section must describe the mandatory procedures for cleaning machinery, equipment and tools, as specified in section 2.3 of this directive. The cleaning sites must be identified and measures for retention and disposal of debris must be described.

It must also specify how the producer intends to educate visitors regarding the cleaning measures (through posters, for example) and how vehicles or machinery not owned by the establishment will be cleaned.

In addition to cleaning machinery, this section must describe the procedures for cleaning all equipment (silos, dryers, probes, personal protective equipment, etc.) that may come into contact with a regulated article. It should also describe the procedures that employees, visitors and others entering a regulated area will have to respect.

A record of cleaning must be kept and made available. A copy of this record must be appended to the Manual.

7. Documents and Records

The establishment should maintain the records that document the activities or procedures related to the measures of this directive for five (5) years. These records must be dated and signed.

Other than the records, below is a list of documents that the establishment must obtain and keep. These documents may be audited by the CFIA. This list is not exhaustive and other documents may be required.

  • Transport documents (bill of lading, etc.)
  • Sale confirmation
  • Storage documents (stock rotation, inventory records, etc.)
  • Documents on the use, processing or repackaging of products
  • Shipping and loading documents
  • Inspection reports and movement certificates (if applicable).

8. Appendices

A copy of all the required records must be attached.