Question Period Note: BULK FERTILIZER LABELLING

Q1 – Why are labels required on bulk fertilizers?
Q2 – Why do labels have to be bilingual?
Q3 – When do bulk fertilizer products need to have bilingual requirements?
Q4 – Why can’t QR codes or digital labels replace physical ones?

R1 - Bulk fertilizers must be accompanied by documentation providing information on their content and how to safely use them, protecting consumers, farmers, the public and Canada’s environment from hazards. The requirement for bulk fertilizer to be accompanied by documentation (its “label”) is consistent with international norms and did not change when the Fertilizers Regulations were modernized in 2020. The only exception is that the information must now be in both official languages.

Bulk fertilizer labels do not need to resemble the complex labels found on consumer products in the home and garden market. A shipping bill or statement containing the information required by the regulations, that accompanies a bulk fertilizer shipment, satisfies this requirement.
R2 - Canada requires bilingual (English and French) product labels to ensure all Canadians have equal access to vital health, safety, and usage information in their official language of choice. While the former Regulations allowed labels to be in English, French, or both, they were not compliant with requirements under the Official Languages Act.
R3 - The Canadian Food Inspection Agency has extended the compliance promotion period for bulk fertilizers until July 31, 2026. The Canadian Food Inspection Agency inspectors will continue to verify compliance with the Regulations and will work with manufacturers to make sure they meet the bilingual requirements by this date. In the event of an urgent safety issue, the CFIA will act immediately to protect consumers and the environment.
R4 - The Fertilizers Regulations state that all required information must be printed on a label conspicuously, legibly and indelibly in English and French. Physical labels that are attached to or that accompany a fertilizer provide key information that enables their safe and effective use.

QR codes do not meet accessibility requirements and are not a replacement for a physical label. Accessing the information behind a QR code requires an electronic device capable of reading them and access to internet or cellular data, which may not be universally accessible through broadband technologies in all areas in Canada where farms are located (e.g. rural communities).

While the European Union recently included support for digital labels in their modernized fertilizers regulations, they retain explicit requirements for physical labels to be displayed at point of purchase and their guidance states that: “labelling information concerning safety and the protection of human, animal, plant health and the environment, on their content and correct use, should always be provided on the physical label.”

The Canadian Food Inspection Agency (CFIA) regulates fertilizers (plant nutrients) and supplements (products that improve the condition of the soil or aid in crop yield) imported into or sold in Canada under the authority of the Fertilizers Act and Regulations.

The CFIA’s fertilizer safety program is focused on user and handler safety as well as environmental safety and mandates that all regulated fertilizer and supplement products be safe for humans, plants, animals, and the environment. Fertilizers must also be properly labelled to provide users and handlers with information enabling safe and appropriate use. The mandate of the Fertilizer Program covers a wide range of products sold for agricultural, commercial, and home and garden use.

The regulatory requirement that bulk products have a label did not change when the Fertilizers Regulations were amended on October 26, 2020.

The language in the current regulations was simplified to require that “all products be labelled”.

When the Fertilizer Regulations were amended in October 2020, they contained a 3-year transition period (until October 2023) to give industry time to adjust to the new regulatory requirements and exhaust old stock. In recognition of the impacts on business caused by disruptions across the value chain due to the pandemic, the CFIA subsequently announced an additional 2-year compliance promotion period (until October 2025) to provide industry with more time to transition. In October 2025, the CFIA announced an additional extension (until July 31, 2026) to provide additional time for the bulk fertilizer sector to develop a path to compliant labelling.

Industry has been informed that a shipping bill that accompanies a bulk product containing the information required by the regulations continues to meet the requirement to “label” a bulk fertilizer. Further clarification was added to the CFIA’s labelling guidance document (T-4-130), in March 2025 to make this explicit.

The Standing Joint Committee on the Scrutiny of Regulations identified that the former Regulations that required that labels be provided in “English, French, or both” contravened the Official Languages Act. The CFIA committed to amending the Regulations to become compliant. The amended Regulations now state that the information required on labels must appear in both languages, in equal prominence and in close proximity to each other. The CFIA cannot authorize unilingual labelling. This key health and safety information must be provided in both official languages as required under the Official Languages Act.

Fertilizer Canada has identified labelling requirements for bulk blend fertilizers (primarily customer formula fertilizers) under the Regulations as being costly. An international scan (covering Canada, USA, EU, UK, Australia and Japan) of labelling requirements for bulk fertilizers shows that Canada is aligned with similar foreign jurisdictions. All reviewed jurisdictions require a label or equivalent document to accompany a bulk fertilizer that: provides guarantees for active nutrients; identifies the responsible party; and provides precautionary information to enable safe and appropriate use thereby protecting humans who are manipulating these chemical compounds. While lot numbers are an exception (not required by USA, Australia or Japan), the CFIA has confirmed to industry that existing invoice numbers, or similar internal tracking numbers, meet the requirement that a label contain a lot number.

Additional points:
1) Although industry identifies the bilingual labelling requirement as costly and burdensome, the CFIA cannot authorize unilingual labelling. Key health and safety information must be provided in both official languages as required under the Official Languages Act.

2) The only change to labelling requirements for bulk-fertilizer blends produced by ag-retailers in response to a grower’s request (customer formula fertilizers) was the requirement for bilingual labels. Precautionary information (including relevant precautionary statements for any pesticidal ingredients) has always been required on labels.

3) The requirement for a bulk fertilizer to be labelled, or accompanied by one, is not new. Approximately 70% of CFIA inspections conducted at bulk fertilizer blending facilities between 2017 and 2020 (when the Fertilizers Regulations were amended) found compliant labels (24/35 inspections). Most non-compliances were corrected through minor label changes.

• The Government is committed to providing Canadian farmers with access to safe fertilizers essential for crop production and the economy.
• The Canadian Food Inspection Agency regulates bulk fertilizers imported or sold in Canada.
• Canadian regulation requires bulk fertilizers to include information in both official languages in accordance with the Official Languages Act.
• Canada’s bulk fertilizer labelling requirements align with international standards and ensure that users are protected when handling these products.
• The Canadian Food Inspection Agency has extended the deadline for bulk fertilizer companies to meet bilingual labelling requirements.