I’ve been answering common questions about CFIA fertilizer registrations. Below, you’ll find a summary of those Q&As, organized by topic for easy reference.
Exemptions
| If I combine EDTA with mineral primary and secondary nutrients, is the product exempt? | No. Chelates are considered supplements and are not on the exemption list. |
| Are all exempt products on the exemption list? | No. A broader description of exempt products is available here: CFIA Fertilizers and Supplements Overview. Primary and secondary mineral-based fertilizers are exempt as long as they do not contain living organisms. |
| Where can I find the exemption list? | Here: List of Primary Fertilizer and Supplement Materials. |
| My product is made of an exempt ingredient on the list, but the description doesn’t fit the exemption criteria. Is it still exempt? | Only if it follows CFIA’s exemption description (see section “Fertilizers exempt from registration”). However, it cannot always be named exactly as it appears on the list. For example, magnesium sulfate under 13% S cannot be called “magnesium sulfate,” but it can be called “sulfate of magnesium.” Example - Rock Phosphate, if it doesn't fit the description on the list, it can be called Phosphate Rock and still be exempt, because it is a mined mineral containing no living material. |
| My product is exempt, is it possible to get a letter from CFIA demonstrating the exemption? | Yes, a letter will be provided, usually within 30 days of submitting required information to demonstration exemption (label, manufacturing, ingredient source and proportions, purpose of the product). |
| Can the same product be exempt or require registration depending on how it is represented? | Yes. If a product is represented as a fertilizer source only, it may qualify for exemption. If the same product is represented as a supplement, or as providing a supplemental function where no exemption exists, it requires registration. |
| Are active supplemental ingredients exempt from CFIA registration? | No. Active supplemental ingredients require registration where no exemption exists. |
| Does a chelated nutrient product automatically qualify for exemption because the nutrient source is exempt? | No. If the product contains an active supplemental ingredient for which no exemption exists, the product requires registration |
| Can an ingredient be added to an exempt fertilizer without requiring registration? | Yes, provided the product continues to meet the criteria for exemption. However, if claims on the label or in marketing materials are attributable solely to the added ingredient, that ingredient is no longer considered inert and the product requires registration. |
| Can performance claims change whether a product remains exempt? | Yes. If a product is represented as providing improved performance that is attributable to an added ingredient, the ingredient is considered active and the product requires registration. If the ingredient is used for another purpose and no performance claims are made, the product may remain exempt. |
| Is an extract of an exempt material automatically exempt? | No. An extract is not automatically exempt because the original material is exempt. |
| Does drying and grinding an exempt material affect its exemption? | No. Drying and grinding do not, by themselves, affect exemption provided the material continues to meet the applicable definition. |
| Can water be added to an exempt material and the product remain exempt? | Yes. Water may be added and the product may remain exempt, provided the active material is still the exempt material. The label should clearly identify the exempt active material. |
| Does an exempt material need to meet its regulatory definition? | Yes. If the material does not meet the applicable definition, it is not exempt and requires registration. |
| Can a material that is not currently exempt be added to the exemption list? | Potentially. Materials may be considered for addition to the exemption list if supporting information is submitted. At this time, additions depend on industry submissions. |
| If an exempt ingredient is present as nanoscale particles, does it remain exempt? | Yes. If the ingredient continues to meet the applicable definition, it remains exempt. The manufacturer remains responsible for ensuring the product is safe and that any claims are not misleading. |
Registration Requirements
| If I’m re-labelling a fertilizer product, do I need to register it? | Yes. However, the wait time is much shorter than for a new product. |
| How long does it take to register a fertilizer or supplement? | In my experience, 12–16 months. |
| If I make a product with both registered and exempt ingredients, do I need to register it? | No, as long as the label is compliant. |
| If I granulate exempt or registered ingredients using a binder, do I need to register it? | No, provided the binder is considered an inert ingredient. |
| Can I change the application rate of a product I am re-packing? | No. The use pattern must remain consistent with the original registered product. |
| I have an organic input approval on a supplement product, can I sell this in Canada? | Only if the supplement is CFIA approved or exempt. |
| Can performance claims change whether a product requires registration? | Yes. If a product is represented as providing improved performance that is attributable to an added ingredient, the ingredient is considered active and the product requires registration. If the ingredient is used for another purpose and no performance claims are made, the product may remain exempt. |
| Can a different microbial strain from the same species be used in a registered product? | No. No changes to a microbial strain are permitted without a major amendment, regardless of safety level. |
| Does the presence of nanoscale particles automatically determine whether a product requires registration? | No. Whether a fertilizer or supplement requires registration or is exempt depends on the material(s) in the product, not on their size. |
| Are nanomaterials classified as Level III for safety assessment? | Yes. Any nanomaterial, whether naturally occurring or intentionally engineered, is classified as Level III for the purposes of registration and requires a full Level III safety assessment. |
| Do inert polymers determine a product's safety assessment level? | No. Inert polymers are reviewed as part of the product's overall safety assessment but do not determine the product's registration safety level. Only the active fertilizer and supplement ingredients are used to determine the safety level designation. |
| Does importing a fertilizer sample for laboratory analysis require regulation under the Fertilizers Act? | If the sample is intended only for laboratory analysis and is not represented as a fertilizer, the import is not regulated under the Fertilizers Act. |
| Does a product intended for research automatically avoid regulatory requirements? | No. Where CFIA confirmed that a product required registration, it also confirmed that a research authorization was required. |
Labels & Language Requirements
| Does the French label need to accompany the product? | Yes. French and English labels must have equal bearing. |
| Am I allowed to include other languages on the label? | Yes, provided the information is not misleading and supports the product description. |
| Can I use my U.S. label in Canada? | Possibly—if it uses metric units and includes all CFIA-required elements (guaranteed analysis, net weight, manufacturer, lot number, cautionary statements, ingredients, first aid, etc.). A French label is still required. |
| The label examples on the CFIA website show Available Phosphoric Acid, can I use Available Phosphate (P2O5)? | The Fertilizers Regulations equate phosphoric acid and phosphate: phosphoric acid or phosphate means phosphorus pentoxide (P205). |
| Can naturally occurring components be guaranteed on the label? | Yes. Where the component is included within the definition of the exempt material, the guarantee does not, by itself, trigger registration. |
| Does a guarantee for a component automatically require registration? | Not always. If the component is specifically included within the regulatory definition of an exempt material, the guarantee does not, on its own, require registration. |
| Can a specific source or species be identified in the "derived from" statement? | Yes. A specific source or species may be identified in the derived from statement. |
Product Use & Blends
| Can I blend my product with another registered product for use on corn and soybean if the label doesn’t list those crops? | No, if the label specifies other crops only. Yes, if the label indicates it is broad-spectrum (all crops). |
Accounts & Access
| How do I set up a CFIA account to submit product applications? | Start here: My CFIA Account Setup. First create an individual account, then set up your company account. |
| My company is U.S.-based—can I create a CFIA account? | Yes, but you’ll need a Canadian resident sponsor to authorize it. |
| How do I transfer a fertilizer registration from one company to another with CFIA? | Fertilizer and supplement registrations are tied to the registrant company. If a product changes hands, Submit a Transfer of Registration request through the CFIA Fertilizer Online Portal. Provide a signed authorization letter from both the current and new registrant, plus company details. Update the product label if the company name or address is changing. Once the transfer is approved, the new company assumes all responsibilities, including renewals, compliance, and tonnage reporting |
Helpful Resource
Search for registered fertilizers and supplements here: CFIA Fertilizer Product Search.
I’ll be attending the Fertilizer Canada Conference, October 31, 2025.
If you have questions you’d like me to ask CFIA directly, send them my way! After the conference, I will release a second Q and A.
