Notice to industry - Labelling of multi-packs and kits containing fertilizers or supplements
April 6, 2021
The fertilizer and supplement industry has expressed interest in marketing products in multi-packs or kits with 2 or more registered or exempt fertilizers or supplements bundled together in a single package. In addition, these kits or a multi-packs may contain both: products regulated under the Fertilizers Act as well as those that fall outside of the purview of the Fertilizers Act such as seeds, growing containers/pots, light fixtures, etc. To promote compliance with the Fertilizers Act and Regulations in the marketplace, the CFIA is providing clarification on the labelling requirements for packages containing multiple fertilizers and supplements that the seller would like to group together as a single saleable item or "kit".
Regulatory requirements under the Fertilizers Act relate to individual products that must be registered or are exempt. Even in the case where all items included are fertilizers or supplements, a kit or multi-pack is treated as a collection of individually regulated products contained within a package. Therefore, the individual products within the kit may require registration or be exempt (refer to registration triggers for fertilizers and supplements for guidance) while the kit does not.
A package includes a sack, bag, barrel, case or any other container in which fertilizers or supplements are placed or packed
The Fertilizers Regulations stipulate that "every package containing" a fertilizer or supplement must meet the labelling requirements. As a result, the individual product and the outer package of a kit are be subject to the labelling requirements (refer to Trade Memorandum T-4-130 for additional guidance).
- Fertilizers or supplements contained in a kit are regulated as individual products and, as such, must be individually labelled in compliance with the Fertilizers Act and Regulations.
- The concept of a "kit" does not include mixing or combining products to create a new product regulated under the Fertilizers Act; in those instances different set of labelling requirements apply.
- The label of each product included in a multi-pack or kit is also required to appear in its entirety on the outer packaging of the multi-pack or kit. For example, if a kit contains 2 fertilizer or supplement products, each individual regulated product is required to be labelled in compliance with the Fertilizers Regulations, and each of those labels must be visible, and legible to the consumer without opening the kit packaging. This requirement may be met through packaging the products in transparent material that permits a potential buyer to read the individual labels in their entirety or, the individual product labels must appear on the outer "kit" packaging.
Contact information:
Fertilizer Safety Section
c/o Pre-market Application Submissions Office (PASO)
Canadian Food Inspection Agency
59 Camelot Drive
Ottawa ON K1A 0Y9
Canada
Phone: 1-855-212-7695
Fax: 613-773-7115
- Date modified: