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T-4- 110 – Requirements for growing media containing fertilizers or supplements

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Effective October 26, 2020, the amended Fertilizers Regulations are in force. Regulated parties can comply with either the "new" regulations or the "old" regulations for a period of 3 years. This applies to the manufacture, sale, import or export of fertilizers and supplements regulated under the Fertilizers Act.

New regulatory requirements (as of October 26, 2020)

1. Purpose

To outline registration and labelling requirements for growing media containing fertilizers or supplements under the Fertilizers Act and Regulations.

2. Exemptions from registration for growing media

According to the Fertilizers Regulations, a growing medium that contains fertilizers, supplements or both is exempt from registration only if each of those fertilizers or supplements is either:

  1. exempt from registration;
  2. registered for use in growing media and its directions for use are consistent with those of the growing media.

Note

Growing media include but are not limited to potting soils, liquid media, coco coir, wood fibers, peat moss, vermiculite, clay, pumice, perlite etc.

Growing media 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 growing medium are not met, the final treated growing medium product requires registration under the Fertilizers Act.

3. Labelling requirements

Growing media that contain fertilizers or supplements, or both, 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

Growing media containing registered fertilizers or supplements (or mixtures thereof) must be labelled with the registration number of each registered component/ingredient it contains.

Also, if the growing medium contains 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 demonstrates that the final product is exempt from registration. The record keeping alternative in lieu of mandatory labelling as described in Trade Memorandum T-4-131 – Record keeping requirements under the Fertilizers Act and Regulations does not apply to growing media.

3.2 Guaranteed analysis

In addition to the information required for all fertilizers and supplements; the guaranteed analysis section on a label of a growing medium must show the minimum percentage of active ingredient(s), expressed on a weight by weight basis of the final mixture/product. For instance, if a growing medium has a bulk density of 0.6 g cm3 and has a fertilizer or supplement that contains 20% of the active ingredient (XXXX) added to it at a rate of 30 g L1, then the percentage of the active ingredient in the final mix is:

[(30 g L1 × 0.2 g g1) ÷ (0.6 g cm3 × 1000 cm3 L1)] × 100 = 1%

The guaranteed analysis section of the label would be as follows:

Guaranteed analysis:
XXXX .................... 1%

Note that this calculation should be made on the assumption that the growing medium is at its maximum moisture content. Growing media that contain a registered fertilizer or supplement must contain those ingredients in amounts that are consistent with the mixing ratios that are recommended on the registered label for that fertilizer or supplement.

3.3 Precautionary statements

The precautionary statements that appear on the label of a growing medium containing a supplement or a fertilizer must include all applicable precautionary statements that appear on the registered product label. If the growing medium is or contains prohibited material as defined in subsection 162(1) of the Health of Animals Regulations, the applicable statements (details found under Tab 2 of the Guide to Submitting Applications for Registration under the Fertilizers Act) are also required.

3.4 Directions for use

Growing media are not required to display direction for use of the fertilizer or supplement product on the label. However, the use patterns for a growing medium containing a fertilizer or a supplement must be consistent with any restrictions that are applicable to the incorporated fertilizer(s) or supplement(s). For example, if the fertilizer or supplement has not been registered for use on food crops, the growing medium which contains such fertilizer or supplement may not direct consumers to use the growing media to grow edible crops.

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

In addition to the requirements under the Fertilizers Act and Regulations, other federal and provincial rules may apply to the import, export, distribution or sale of growing media. For example, soil and soil-related matter, including growing media are an internationally recognized pathway for the spread of plant pests. The CFIA establishes and maintains policies and standards, under the authority of the Plant Protection Act and Regulations, relating to the importation and domestic movement of soil and soil-related matter to prevent the introduction and spread of regulated pests into Canada. Please refer to the CFIA's Soil and soil-related matter website for additional information about phytosanitary requirements that may apply to a specific activity.

5. 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
Email: cfia.paso-bpdpm.acia@inspection.gc.ca

Old regulatory requirements (until October 26, 2023)

September 1997

According to the Fertilizers Act, a supplement is defined as:

Any substance or mixture of substances, other than a fertilizer, manufactured, sold or represented for use in the improvement of the physical condition of soils or to aid plant growth or crop yields.

Supplements, other than those exempted from registration in Section 3.1(3) of the Fertilizers Regulations, must be registered prior to being imported into or sold in Canada. On this basis, potting soils that contain, or are represented to contain supplements have required registration. On 11 May 1993, section 3.1(3) of the Fertilizers Regulations, was amended to contain the following subsection:

3.1 (3) The following fertilizers and supplements are exempt from registration:

(h) potting soils that contain supplements, if those supplements are registered under the Act.

Thus, potting soils that contain registered supplements are no longer required to be registered under the Fertilizers Act. They are, however, subject to the labelling, standards, and guaranteed analysis requirements that are identified in the Fertilizers Regulations. In addition, labelling must be in accordance with any use conditions to which the registered supplement is subject.

These requirements are discussed in the sections that follow.

General Labelling Requirements

A potting soil containing a supplement registered under the Fertilizers Act must conform to the labelling requirements for supplement products. Labelling requirements are found in Section 18. of the Fertilizers Regulations. A label for a potting medium containing a supplement must include the following information:

  • the name and address of the manufacturer of the product;
  • the name of the product;
  • the weight of the product;
  • the directions for use;
  • the guaranteed analysis, as prescribed in section 15, including
  • the minimum percentage of the supplement active ingredient, expressed in percent on a weight by weight basis;
  • the date beyond which the product is not intended for use, if applicable;
  • the registration number of the supplement; and
  • precautionary statements, where applicable.

Product Weight

Because potting media are subject to changes in moisture content, the requirements that the weight of the potting soil be printed on the package, and that the active ingredient be guaranteed on a percentage weight by weight basis, concern some manufacturers. To avoid problems with these measurements, the weight of final product should be guaranteed at the minimum moisture percentage of the potting soil, and the percentage of active ingredient in the product should be calculated at the maximum moisture percentage of the product.

Direction for Use

Directions for use of a potting soil containing a supplement must be consistent with any restrictions that are applicable to the supplement itself. For example, if a supplement has not been registered for use on food plants, a potting soil which contains the supplement may not make reference to such use, or imply that such use is acceptable.

Guaranteed Analysis

The guaranteed analysis section of the potting soil label must show the minimum percentage of active ingredient, expressed on a weight by weight basis. For instance, if a potting soil has a bulk density of 0.6 g cm3 and has a supplement that contains 20% of the active ingredient (XXXXX) added to it at a rate of 30 g L1, then the percentage of supplement active ingredient in the final mix is:

[(30 g L1 × 0.2 g g1) ÷ (0.6 g cm3 × 1000 cm3 L1)] × 100 = 1%

The GUARANTEED MINIMUM ANALYSIS section of the label would be as follows:

GUARANTEED MINIMUM ANALYSIS:
XXXXX .................... 1%

Note that this calculation should be made on the assumption that the potting soil is at its maximum moisture content.

This section must also show the registration number of the supplement that the potting medium contains. For example, the package might show the following:

GUARANTEED MINIMUM ANALYSIS
XXXXX .................... 1%*

* derived from Registration Number XXXXXXA Fertilizers Act

The registered trade name of the product may be identified, if the manufacturer wishes to do so. The trade name must not appear in the guaranteed minimum analysis section, but may appear in the section preceded by the asterisk.

Precautionary Statements

The precautionary statements that appear on the label for a potting soil containing a supplement must include all applicable safety statements that appear on the registered supplement label.

Standards

Amount of Supplement in Potting Soil

Potting soils that contain a registered supplement must contain that supplement in an amount that is consistent with the mixing ratios that are recommended on the registered label for that supplement.

Acceptable Claims

Claims that are made about the potting soil must be consistent with the accepted claims for the registered supplement. Claims other than those that are accepted for the registered product must be substantiated prior to the sale of the potting soil containing the supplement.

For further information, please contact:

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
Email: cfia.paso-bpdpm.acia@inspection.gc.ca

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