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D-17-01: Canadian Peat Export Certification Program

Effective date: August 11, 2023
(Original)

Subject

This directive describes the Canadian Peat Export Certification Program (CPECP), which provides the basis for phytosanitary certification of peat-based commodities from Canada.

On this page

1.0 Legislative authority

2.0 Definitions, abbreviations and acronyms

Definitions of other terms used in the present document can be found in the Plant Health Glossary of Terms or in the International Standard for Phytosanitary Measures (ISPM) 5: Glossary of phytosanitary terms.

Peat
For the purposes of this directive, the term "peat" indicates Sphagnum peat moss (see Introduction for details). Commercially packaged peat may also be labelled as peat moss, bulk peat and/or natural peat moss.
Preventive control plan (PCP)
Describes a systems-based approach developed by regulated parties of the CFIA that focuses on prevention as a way to achieve compliance.
Sector
For the purpose of this directive the term "sector" refers to areas of a bog (fen or mire) that have been prepared for harvest and used for export.

3.0 Introduction

Peat is the non-viable, incompletely decomposed organic residues of plants, often mosses, accumulated under anaerobic, acidic conditions. While Canada produces several types of peat for horticultural purposes,including Sphagnum peat moss, Hypnum peat, reed peats and sedge peats, this directive only applies to Sphagnum peat moss, referred to in the remainder of this document as peat.

Note: Sphagnum moss (as opposed to Sphagnum peat moss) is a product derived from living mosses that are harvested and dried. It is not considered peat and is not within the scope of this directive.

Phytosanitary risk associated with peat is minimal due to the following characteristics:

  1. peat has a low nutritional value
  2. peat bogs are generally acidic
  3. peat bogs are generally free from soil; however, soil contamination can occur
  4. solar heat used to dry the upper layer of peat in the bog for harvesting reduces the viability of pests
  5. impurities present in the peat are removed during processing and packing
  6. most fungal and bacterial pathogens cannot decompose the Sphagnum spp. cell walls

Peat plays an important role in horticultural practices as a growing medium and soil amendment used by home gardeners, professional nursery growers and landscape businesses to enhance the water retention capabilities of soils. Commercial peat originates predominantly from natural peat bogs with a peat thickness of 2 meters or greater and an area of 50 hectares or greater. Peat bogs across all Canadian provinces cover more than 100 million hectares.

The Canadian Peat Export Certification Program (CPECP) provides a voluntary means for peat harvesters, processors and exporters (including brokers) to obtain phytosanitary certification of peat-based commodities destined for export to countries that require phytosanitary certification. Prior to the approval of any bog under the CPECP, a representative of the peat bog (referred to as the peat representative in the remainder of the document), must submit a Preventive Control Plan (PCP) to the CFIA communicating information pertinent to the export certification of peat (Annex 1). Information provided in a PCP is used by the CFIA to conduct inspections and aid in sample site selection. Sample analysis provides assurance that contaminants like soil, sand, plant parasitic nematodes and non-peat plant debris are excluded from products being prepared for export (additional sampling may be required depending on the importing countries requirements). Development and implementation of a PCP in addition to ongoing inspection and sampling (1/3 of the bog each year) of peat bogs ensure that commodities presented for export are compliant with the foreign country's phytosanitary import requirements.

4.0 Scope

4.1 Regulated pests

Peat samples collected by the CFIA for the purpose of peat bog certification are tested for the presence of soil, sand, plant parasitic nematodes and non-peat plant debris. Other tests may be performed in order to satisfy the phytosanitary import requirements of destination countries.

4.2 Regulated articles

4.3 Commodities that are outside the scope of this directive

4.4 Regulated areas

Peat bogs in Canada from which peat is harvested for the purpose of export to countries that require phytosanitary certification.

5.0 Phytosanitary export requirements

5.1. General requirements

All peat intended for export must be free from sand, soil, plant parasitic nematodes and non-peat plant debris (not typically associated with sub-surface peat).

The peat representative or peat processing/packing facility must employ practices to exclude soil, sand, plant parasitic nematodes and non-peat plant debris from their bogs and harvested peat. Brokers are to ensure that peat intended for export has been harvested from establishments who hold current PCP's or have final products sampled before every export.

Traceability of peat intended for export must be maintained throughout harvesting, processing and packing. The PCP must include a traceability system which must be capable of tracing a packaged lot back to the sector of the bog from which it was harvested. This is significant if the CFIA was required to re-sample. Failure to adequately maintain traceability may result in otherwise compliant material not qualifying for export under the program. This may also result in follow up actions applying to a larger area or sector than necessary if the CFIA were to received communication from a importing country indicating non-compliance. Brokers exporting peat from approved establishments should also have an approved traceability program in place. The local CFIA office can work with exporters to develop the PCP to satisfy traceability requirements.

To obtain a phytosanitary certificate, an Application for Export Inspection and Phytosanitary Certification (Form no. 3369) must be completed and provided to the local CFIA office.

Phytosanitary certification must be in accordance with the CFIA's Plant Health directive D-99-06: Policy on the issuance of phytosanitary certificates and phytosanitary certificates for re-export, as well as the phytosanitary import requirements set by the destination country's National Plant Protection Organization (NPPO).

5.2 Specific phytosanitary certification methods for peat

There are 2 phytosanitary certification methods available for peat for export:

Note: A combination of these certification methods may be used to satisfy the phytosanitary import requirements of certain destination countries.

The certification methods differ in the amount of advanced notification recommended by the CFIA to conduct inspection and sampling, time required to complete inspections and the amount of peat that can be certified. Sections 5.2.1 and 5.2.2 below provide an overview of the two certification methods.

5.2.1 Phytosanitary certification based on bog inspection and sampling of a peat bog under a PCP (for exporters approved under the CPECP)

PCPs inform the CFIA of practices employed by peat harvesters, processors and exporters that may impact the phytosanitary status of peat-based commodities destined for export. The information provided in a PCP guides inspectors during bog inspection and is considered during issuance of a phytosanitary certificate. .

Bog inspection and sampling consists of visual inspection of the bog site and surrounding area, interviews with key staff and collection of samples from various sites within the bog. The CFIA inspectors will inspect and sample bogs and associated facilities or equipment (if applicable), and will audit records as deemed appropriate based on the information provided to the CFIA in Annex 1: Preventive control plan (PCP) for export certification of peat-based commodities under the Canadian Peat Export Certification Program.

The peat representative, or a delegate, must be present at the time of inspection and may be expected to facilitate the inspection by providing the following:

Samples are submitted by the CFIA inspectors for laboratory analysis to test for the presence of soil, sand, plant parasitic nematodes and non-peat plant debris. Additional testing of end product may be required to satisfy a foreign country's phytosanitary import requirements.

Inspection and sampling of established peat bogs is conducted 6 months in advance of date of export according to requirements listed in the summary of program requirements (section 7.0). The bog site is inspected annually. Sampling is conducted on one third of the site, on a rotating basis, ensuring that the bog is inspected and sampled completely every three years.

If bog buffer zones are harvested for export this must be declared on the PCP to ensure sampling is conducted.

In cases where the depth of harvest exceeds that which is declared in the PCP, or the bog has been manipulated or worked in a way that exposes peat that has not been inspected and sampled, the peat representative must contact their local CFIA office to request an additional inspection prior to export. The CFIA recommends at least one month's notice to accommodate additional inspection(s) for this activity.

Ongoing bog inspection and sampling of a peat bog allows for certification of all sampled peat sectors from that bog, and offers several other benefits to the exporter, including:

Note: End product inspection (section 5.2.2) may still be required to satisfy the phytosanitary import requirements of certain destination countries.

5.2.2 Phytosanitary certification based on inspection and sampling of end products (for exporters not approved under this CPECP)

Registration under the CPECP is encouraged however it is a voluntary program. Exporters may choose to request certification of end product, which entails inspection and sampling of the commodity after it has been harvested, processed and packaged. Note: Brokers of peat commodities made from peat sourced from an approved CPECP bog will likely not need additional product inspection and sampling.

In that case, the following requirements apply:

5.3 Program participation

Bogs must be located in Canada in order to be eligible for participation in the CPECP. It is the responsibility of the exporter to ensure all peat exported (under the umbrella of the exporter/broker) have a valid PCPs.

Prior to the approval of any bog under the CPECP, a peat representative must complete Annex 1: Preventive control plan (PCP) for export certification of peat-based commodities under the Canadian Peat Export Certification Program and submit it to their local CFIA office at least 6 months in advance of the expected date of export. The CFIA will review the information submitted and may provide comments or suggestions for modification of the document prior to inspection of the bog.

PCPs will not be approved by the CFIA until an inspection of the bog site has been completed. Following inspection, the CFIA may request that the peat representative modify the PCP until it has been reviewed and approved by a CFIA employee (usually from the local CFIA office) and returned to the peat representative.

Following approval to participate in the CPECP, the peat representative must contact the CFIA annually or as instructed by an inspector to request inspection under the CPECP. Failure to contact the CFIA, as described above, may result in suspension from the program.

PCPs must be maintained and reflective of the practices or procedures actively used in the bog. Any revision of the document must be submitted to the CFIA for approval. For example, a PCP must be revised if peat is to be harvested for export from a new sector of the bog.

Deviation from the PCP may require the CFIA to inspect end product and/or may lead to delays in export certification. It is recommended that changes to PCPs be communicated to the local CFIA office well in advance of export.

Program participants that have withdrawn or have been suspended from the program must re-submit their PCP in order to re-join the program.

6.0 Regulated article treatment

Various treatments may be required for shipments of peat when stipulated in the phytosanitary import requirements of the destination country.

The exporter must provide details of the treatment to the CFIA for evaluation and pre-approval. Treatment details may be submitted to the CFIA, in writing, either accompanying a PCP or 2 months prior to the expected date of export. Especially complex treatments may require additional time for review and approval; contact your local CFIA office for more information.

Only treatments pre-approved by the CFIA will be considered during the issuance of phytosanitary certificates.

7.0 Summary of program requirements

For exporters approved under the CPECP For exporters NOT approved under the CPECP
Certification method Bog inspection and sampling of a peat bog (5.2.1) Inspection and sampling of a end product (5.2.2)
Amount of peat that can be certified for export Any portions of the bog that have been inspected in the preceding 3 years to a depth no greater than declared in the PCP.

Depends on size of lot(s).

One-time certification of specific lot(s).
Phytosanitary Certificate Application requirements
  • form 3369 must be completed in full for each phytosanitary certificate requested, including traceability to the sector of the bog from which the peat was harvested.
  • form 3369 must be completed in full for each phytosanitary certificate requested.
  • reference to the bog(s) from which the peat was harvested should be included, when applicable.
Advance notification recommended for phytosanitary certification application and sampling

Once, annually, at least 6 months in advance of the expected date of export for inspection and sampling.

For facilities where the depth of harvest exceeds what is listed in the PCP, a minimum of 1 month notice is required for additional inspection and sampling.

 At least 1 month in advance of each expected date of export.
Advance notification recommended for approval of the commodity treatment, if applicableTable Note * Submitted with PCP or 2 months prior to expected date of export. 2 months prior to expected date of export.
Ongoing requirements Yes – contact the CFIA annually to schedule inspection or as directed by an inspector. No ongoing requirements.

8.0 Non-compliance

The CFIA will follow the Compliance and Enforcement Policy when informing regulated parties, assessing and monitoring compliance, and responding to instances of non-compliance. Any costs incurred due to non-compliance or violation (disposition, removal, etc.) will be the responsibility of the owner, importer, or the person having possession, care, or control of the thing.

Notifications of non-compliance will be issued in accordance with D-01-06: Canadian Phytosanitary Policy for the Notification of Non-compliance and Emergency Action.

Peat harvested from bogs found to be non-compliant due to the presence of soil, sand, plant parasitic nematodes and non-peat plant debris will not be eligible for certification based on bog inspection and sampling of a bog (section 5.2.1). Certification based on inspection and sampling of end product (section 5.2.2) may be used in these cases.

Subject to the inspector's discretion, a PCP may be modified during or following an inspection in order to bring a non-compliant bog into compliance. For example, a bog's representative may decide to expand a buffer zone to ensure that soil, sand, plant parasitic nematodes and non-peat plant debris are not harvested. All modifications of the PCP must be approved by the CFIA prior to issuing a phytosanitary certificate.

Phytosanitary certificates will not be issued for peat that does not meet the importing country's phytosanitary import requirements.

9.0 References

9.1 Fees

The CFIA charges fees in accordance with the Canadian Food Inspection Agency Fees Notice, including for inspections and sampling associated with the Canadian Peat Export Certification Program. Fees may also be collected by the Canada Border Services Agency on behalf of the CFIA. For information regarding fees associated with inspection and movement of regulated articles, please contact a local CFIA office or visit the Fees Notice web page.

9.2 Supporting documents

Annex 1: Preventive control plan for phytosanitary certification of peat-based commodities under the Canadian Peat Export Certification Program

Eligible bog representatives must complete all sections of the PCP or provide rationale for any questions that are not answered.

Information provided to the Canadian Food Inspection Agency (CFIA) in this PCP will be used to determine inspection priorities, sampling needs and facility compliance with import countries requirements.

This PCP must be implemented and reflective of the practices and/or procedures used in the bog. The peat representative is responsible for informing the CFIA, in a timely manner, of any deviation from the processes described in the PCP.

Multiple bog sites may be included in a single agreement as long as sufficient detail is included to describe the practises occurring at each site.

Company name: space

Name of bog representative responsible for PCP: space

Office Address: space

Telephone Number: space

Email address: space

  1. Is the peat being exported to a country other than the United States?

    • Yes
    • No

    If yes, indicate planned destinations:

  2. Is it possible that peat harvested from your bog(s) could be exported by another company (example: broker)?

    • Yes
    • No
    • Unknown

    If yes, please provide for each bog, the company's name and address:

  3. Are you exporting peat harvested from peat bogs owned or operated by another company?

    • Yes
    • No

    If yes, please provide the company name, address of company and address of bog:

  4. Attach a map with scale for each peat bog from which peat will be harvested for export (example: aerial photo), include the following information:

    • Physical location or address of the bog, including a unique identifier for each sector within
    • Shape of the bog, clearly indicating the perimeter.
    • Any evident, permanent landmark features (if applicable)
    • Size of the bog in use (in hectares).
    • Location of access roads, drainage ditches and an indication of the size of buffer zones (indicate those zones suitable and unsuitable for harvest) surrounding those features.
    • Buffer layer – a certain thickness of peat layer that might contain soil or sand on the top of the bog.
    • Portion(s) of the bog that will be harvested, if the entire bog will not be harvested. Include number of years the bog has been in production, its expected commercial lifespan and the total area to be harvested (in hectares)
    • Estimated depth of harvest per year. If depth of harvest is variable between bogs this must be indicated for each sector.

    Note: This value will be used to determine the depth from which samples are collected; care should be taken to not underestimate depth of harvest.

  5. Describe how traceability of peat is maintained from harvest to packaging. Include a description of how this information is recorded and how long records are maintained.

  6. Describe the procedures used to harvest, store, process and package peat for export, especially any steps that may exclude contaminants: i.e. soil, sand plant parasitic nematodes and non- peat plant debris. In addition to general procedures, also describe:

    • How peat destined for export is identified to ensure no mixing with peat destined for other end uses or from sectors not yet sampled (e.g., bales of peat are identified by a batch number, which makes it possible to identify its precise content and to trace the sector(s) where the peat was harvested).

  7. Describe what measures are taken to avoid harvesting peat from sectors of the bog where contaminants are known to occur. For example:

    • Soil, sand, plant parasitic nematodes and non- peat plant debris
    • Establishment, demarcation, and maintenance of buffer zones
    • Contaminated sectors that are harvested and deposited in a waste pile that is marked and maintained separate from export-quality peat
    • Procedures for operating staff to follow in these sectors

  8. Describe how employees are trained on the procedures listed above and how training records will be maintained.

Name of company's representative: space

Signature: space

Date: space

Please forward a signed copy of this PCP to your local Canadian Food Inspection Agency office. A letter of field sampling results will be provided to the applicant upon review and approval by the CFIA.

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