The modernized Fertilizer Regulations have introduced labeling requirements for bulk shipments that are generating significant concern within the fertilizer industry. Fertilizer Canada is working on addressing the hurdles in meeting the new labelling requirements with CFIA and will be providing further details on a path forward in the New Year.
As per the Act: a package includes a sack, bag, barrel, case or any other container in which fertilizers or supplements are placed or packed. So, anything containing a regulated material is a “package”, and must have a label affixed or accompanying it that meets the requirements of the Regulations. In cases of large bulk volumes (e.g. truckload), that can be met through the shipping bill or invoice having printed on it the mandatory information. Alternatively, a paper label can be printed to accompany the bulk lot. Trade memorandum T-4 130 outlines labelling requirements and includes sample labels.
While the requirements aim to ensure regulatory compliance and traceability, they are viewed as overly burdensome, particularly for low-risk fertilizers. The industry is struggling with the practicalities of implementing these requirements, especially for blended products and meeting French/English labelling obligations.