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

1. Purpose

The purpose of the document is 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; or
2. registered for use in growing media and its directions for use are consistent with those of the growing media.

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.

Note: growing media products are those represented as providing a substrate in which plants can grow and include, but are not limited to, potting soils, liquid media, coco coir, wood fibers, peat moss, vermiculite, clay, pumice, perlite, etc.

3. Labelling requirements

Growing media that contain fertilizers and/or supplements are regulated under the Fertilizers Act and regulations and have unique labelling requirements.,

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 exempt ingredients, one of the following must be included on the label for each exempt ingredient, in order to demonstrate that the final product is exempt from registration:

1. the term for each fertilizer or supplement material present on the List of Materials; or
2. a statement that each fertilizer ingredient (not included on the list of materials) is exempt because it is not produced or derived from a living organism.

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.

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

A growing media product that contains fertilizer(s) and/or supplement(s) and that is represented solely for use as a substrate to grow plants in (that is to say, to be used in pots or containers to provide a substrate in which plants can be grown) are not required to include directions for use on the growing media label. However, the use patterns for that growing medium product 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.

Regulated growing media products labelled with directions for use consistent with a fertilizer or supplement (not solely represented as a substrate in which plants can grow) are themselves regulated as fertilizers or supplements and do not have access to the reduced labelling requirements associated with growing media. Examples of representation as a supplement include: "mix into soil, blend into existing soil or apply as top dressing". Similarly, growing media that are represented for application as a source of plant nutrients are regulated as fertilizers. In these instances, products require complete directions for use, and if marketed without them, are considered non-compliant with the labelling requirements and may be subject to enforcement action. For guidance on requirements for directions for use, please refer to Trade memorandum T-4-130.

4. Compliance determination for growing media without directions for use

Growing media that are not required to have complete directions for use on the label do not have application rate that can be used to verify compliance with safety limits for metals, dioxins and furans. To enable compliance verification with the safety standards, the CFIA uses a standard 45 year application rate of 2,000,000 kg/ha (annual application rate of 44,444.44 kg/ha). For more information, please refer to trade memorandum T-4-93.

5. 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.

6. Contact information

Fertilizer Safety Section
Canadian Food Inspection Agency
Phone: 1-855-212-7695
Email: cfia.paso-bpdpm.acia@inspection.gc.ca