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T-4- 105 – Requirements for seeds treated with fertilizers or supplements

The 3 year regulatory transition period (October 26, 2020 to October 26, 2023) has now ended. As a result, regulated parties, including all manufacturers, importers, distributors and sellers of fertilizers and supplements must adhere to the amended Fertilizers Regulations. There are few notable exceptions for some product categories. Learn more about the implementation of the amended Fertilizers Regulations.

1. Purpose

The purpose of the document is to outline registration and labelling requirements for seed treated with fertilizers or supplements under the Fertilizers Act and Regulations.

2. Exemptions from registration for treated seeds

The Fertilizers Regulations exempt seeds treated with fertilizers, supplements or both, only if each of those fertilizers or supplements is either:

  1. exempt from registration; or
  2. is registered for use with those seeds

Treated seeds that meet the exemption from registration above are still subject to safety standards and labelling requirements as prescribed in the Fertilizers Regulations. If the above conditions (a-b) for each of the fertilizers or supplements added to the seed are not met, the final treated seed product requires registration under the Fertilizers Act. Note that treating seeds with fertilizers or supplements is not considered manufacturing. Therefore, the exemption for fertilizers and supplements imported or manufactured in Canada for manufacturing purposes only does not apply to seed treatments.

3. Labelling requirements – Fertilizers Act

Seeds treated with fertilizers or supplements meet the definition(s) of a fertilizer or supplement and as such are subject to the same requirements prescribed by the Regulations as fertilizers or supplements themselves.

3.1 Mandatory labelling of registered or exempt ingredients

Seeds treated with registered fertilizers or supplements or mixtures thereof must be labelled with the registration number of any registered component/ingredient it contains. If the seed is treated with one or more fertilizer or supplement material(s) present on the List of Materials the term for each component must be included on the label together with any other information that is sufficient to demonstrate that the final product is exempt from registration. The record keeping alternative in lieu of mandatory labelling as described in Trade Memorandum T-4-130 does not apply to seeds treated with fertilizers or supplements.

3.2 Guaranteed analysis

In addition to the information required for all fertilizers and supplements; the guaranteed analysis section on a label of seeds treated with a fertilizer or supplement must show the minimum percentage of active ingredient(s), expressed on a weight by weight basis of the final treated product. For instance, if seeds have a bulk density of 720 kg/m3 and are treated with a fertilizer or supplement that contains 20% of the active ingredient (XXXX) added at a rate of 0.15 L/kg1seed, then the percentage of the active ingredient in the final, treated product is:
[(0.15 L/kg1 x 0.2) ÷ (720 kg/m3 x 0.001 m3/L)] x 100 = 4.2%
The Guaranteed analysis section of the label would be as follows:
Guaranteed analysis:
XXXX .................... 4.2%

3.3 Precautionary statements

The labels/seed tags of treated seed products (whether sold in bags or bulk) must contain all applicable precautionary statements that appear on the registered fertilizer or supplement label. For safety standards for fertilizers and supplements please refer to Trade memorandum T-4-93.

3.4 Directions for use

Where a seed is treated with fertilizers, supplements or both, the product label for the treated seed is not required to bear directions for use associated with the fertilizers or supplements with which the seeds were treated.

4. Requirements other than those under the Fertilizers Act and Regulations

4.1 Seeds Act and Regulations

While the Fertilizers Act and Regulations contain requirements for seeds treated with fertilizers or supplements, or both, this is not the sole piece of federal legislation that contains requirements for seeds. The CFIA's Seed Section is responsible for the administration of the Seeds Act and Regulations to help ensure that seeds sold in, imported into and exported from Canada meet established standards for quality and are labelled so that they are properly represented in the marketplace, and the variety is registered prior to sale in Canada (most agricultural crop varieties). Please refer to the CFIA Seed Section's website for additional information regarding import and export requirements, industry guidance, inspection procedures, testing and grading of seeds.

5. Contact information

Fertilizer Safety Section
Canadian Food Inspection Agency
Phone: 1-855-212-7695

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