Archived - T-4-110 - Potting Soils Containing Products Regulated as Supplements Under the Fertilizer Act
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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.
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.
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 x 0.2 g g1) ÷ (0.6 g cm3 x 1000 cm3 L1)] x 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.
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.
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.
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
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