T-4- 124 – Export certificates under the Fertilizers Act
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.
The purpose of this document is to outline the information requirements for obtaining an export certificate for fertilizers and supplements intended for export and labelled accordingly and describe the process for reviewing applications.
Export certificates certify that the product met the Canadian regulatory requirements with respect to product safety and identity, but does not confirm compliance with the labelling requirements prescribed in the Fertilizers Act and regulations as labelling requirements may vary significantly between countries. Export certificates are issued to facilitate the export of products from Canada, but are not a mandatory requirement for export. This service is provided on request in order to support foreign market access for Canadian fertilizers and supplements. The authority to issue export certificates is provided by the Fertilizers Act and the Fertilizers Regulations.
Possession of an export certificate does not exempt a product from marketplace monitoring if the product is sold in Canada. When found in the marketplace, Non-compliant products may be subject to enforcement action including product detention and, in cases of repeated or severe contraventions, prosecution. Furthermore, a contravention of the Fertilizers Act and regulations invalidates the export certificate.
It is the responsibility of the manufacturer/distributor/retailer to ensure that the product continues to meet the requirements of the Fertilizers Act and regulations and associated policies as they may change over time. Failure to do so may render an export certificate invalid. Furthermore, the export certificate issued by the Canadian Food Inspection Agency (CFIA) does not exempt the product from the applicable provincial and/or municipal regulations and requirements if and when the product is sold in Canada.
The review of the information provided in support of an export certificate does not involve consideration of the requirements (regulatory or otherwise) of the importing country. It is the responsibility of the exporter to ensure that requirements of the destination country are complied with prior to exportation.
Products eligible for export certification include:
- Products comprised of fertilizer and supplement materials as they appear on the List of Primary Fertilizer and Supplement Materials (List of Materials) as long as they meet the term (definition and compositional criteria) prescribed on the List of Materials
- Mixtures of materials that appear on the List of Materials, as long as the material meets the compositional criteria for the term and meet the term and compositional criteria for that term
- Products that are otherwise exempt from registration and
- Products that are currently registered under the Fertilizers Act
4. Conditions and limitations
- The export certificate applies only to the product for which a certificate was granted.
- The assessment is based on the review of information provided by the applicant/product proponent in their application.
- Any changes made to the ingredients in the final product and/or their sources or the manufacturing process will invalidate the certificate.
- The review of the safety and identity information does not include a comprehensive label review or verification of the quality or performance of the product as the latter lie outside the mandate of the CFIA and the Fertilizers Act and regulations.
- Additional analysis may be requested at varying intervals to ensure certificate remains valid.
- The certificate is valid for 1 year.
5. Information requirements
In order to receive an export certificate, the application must demonstrate that the product met the Canadian requirements with respect to the safety and identity of the product when it is used according to directions. As such, only the portions of the label that impact the safe and sustainable use of the product (for example directions for use, precautionary statements and/or instructions for use of personal protective equipment) are considered as part of the evaluation. The following information is required to enable the review in support of issuing an export certificate:
- Cover letter
- A complete list of all constituent materials (including the active ingredients and inert formulants), their sources and origin and proportions in the final product (CAS # should be included if available)
- Detailed description of the method of manufacture including all applicable quality control and quality assurance methods used
- Results of analyses for contaminants of concern which may include metals, indicator organisms, and/or dioxins and furans (for further guidance on what results of analysis are required per product type are listed in Appendix 1 below); for prohibitions and safety standards applicable to all fertilizers and supplements please refer to Trade Memorandum T-4-93
- Results of analysis demonstrating the identity of the product (for example nutrient content analysis)
- Copy of the proposed label, or the text that is proposed to appear upon it (directions for use, precautionary statements, protective equipment, etc.)
Please note that submission of results of analysis at certain intervals during the period when the certificate is valid may be required.
6. Review process and service delivery standards
Please direct all applications for export certificates to:
Pre-market Application Submissions Office
A submission control number will be assigned to the file and an acknowledgement email will be sent to the applicant within 5 working days of the receipt. Applicants are strongly encouraged to ensure that their applications are complete and well organized – it is recommended to follow the same format as for the registration applications described in the Guide to Submitting Applications for Registration Under the Fertilizers Act.
Furthermore, if deficiencies or data gaps are identified – it is important that the applicant(s) respond quickly and comprehensively – otherwise the file will be closed and returned to the applicant (on request). There are currently no service delivery standards associated with the review of applications for export certificates. Nevertheless, the CFIA appreciates the importance of timely review and issuance of the certificates.
The timelines will also depend on the extent of the review that is required; for example products that are currently registered for sale in Canada will not require a substantive review as the safety and identity information would have already been evaluated during registration.
There are currently no fees in the CFIA User Fees Notice applicable to this service and so the service will be provided free of charge. However, the CFIA is in the process of reviewing its fee structure for all commodities and services and it is anticipated that issuing export certificates for fertilizers and supplements will be subject to cost recovery in the future.
8. Contact information
Fertilizer Safety Section
Canadian Food Inspection Agency
|Term||Metals||Dioxins and furans||Indicator organisms|
|Ammonium nitrate or AN||Check|
|Ammonium phosphate sulphate or APS||Check|
|Ammonium sulphate or AS||Check|
|Aqua ammonia or ammonia liquor||Check|
|Blood and Bone meal||Check||Check|
|Calcium ammonium nitrate decahydrate or calcium ammonium nitrate double salt||Check|
|Calcium ammonium nitrate or CAN||Check|
|Calcium ammonium trinitrate||Check|
|Calcium and magnesium nitrate||Check|
|Calcium nitrate or nitrate of lime||Check|
|Diammonium phosphate or DAP||Check|
|Dimethylenetriurea or DMTU||Check|
|Garbage tankage, Residential tankage or Biogenic waste||Check||Check|
|High-analysis superphosphate or anydrous superphosphate||Check|
|Hoof and horn meal||Check||Check|
|Isobutylidene diurea or I.B.D.U.||Check|
|Magnesium ammonium nitrate||Check|
|Magnesium ammonium sulphonitrate||Check|
|Manure or composted manure||Check||Check|
|Methylenediurea or MDU||Check|
|Monoammonium phosphate or MAP||Check|
|Muriate of potassium or potassium chloride||Check|
|Nitrate of potash or potassium nitrate||Check|
|Nitrogen solutions (non-pressurized)||Check|
|Nitrogen solutions (pressurized)||Check|
|Potash manure salts or mine run potash salts||Check|
|Single superphosphate, ordinary superphosphate, normal superphosphate or super 20||Check|
|Sodium and potassium nitrate or nitrate of soda and potash||Check|
|Sodium nitrate or nitrate of soda||Check|
|Struvite or magnesium ammonium phosphate||Check|
|Sulphate of potash or potassium sulphate||Check|
|Sulphate of potash-magnesia; potassium-magnesium sulphate; double-sulphate of potash and magnesia; double sulphate of potassium and magnesium; or langbeinite||Check|
|Sulphur coated urea or SCU||Check|
|Superphosphoric acid or SPA||Check|
|Tankage or animal tankage||Check||Check|
|Triple superphosphate or triple||Check|
|Urea phosphate or carbamide phosphoric acid||Check|
|Urea-ammonium nitrate or UAN||Check|
|Urea-formaldehyde or urea-form||Check|
|Term||Metals||Dioxins and furans||Indicator organisms|
|Calcitic limestone or calcite||Check|
|Coir or coconut coir||Check||Check|
|Dolomitic limestone or dolomite||Check|
|Gypsum or landplaster||Check|
|Peat, peat moss, or sphagnum moss||Check||Check|
|Pozzolan or diatomaceous earth||Check|
|Quicklime, burnt lime, or caustic limescope="col"||Check|
|Spent mushroom media||Check||Check|
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