T-4-123 - Labelling of Low and No Phosphate Lawn / Turf Fertilizers under the Fertilizers Act and Regulations

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March 2017

1. Introduction

1.1 Purpose

The objective of this document is to describe the labelling requirements and guaranteed nutrient tolerances for Low and No phosphate specialty fertilizers, intended for use on lawns and turf. Establishment of a Low and No phosphate policy will ensure that such products have accurate label representation, and consumers, as well as other regulatory bodies (federal, provincial and municipal), can readily identify these products in the marketplace.

1.2 Background

Several regulatory jurisdictions are developing restrictions on the use of phosphorus in turf and lawn fertilizers, with the intent of mitigating nutrient runoff into rivers, lakes, and wetlands. Although phosphorus is an essential element required to support the normal growth and development of all plants, its excessive addition into watercourses can cause, or accelerate, eutrophication. Eutrophication is a process by which nutrient rich aquatic environments result in increased plant growth and consequently a significant reduction in water quality. Phosphorus additions into watercourses can come from a variety of different sources including: leaves, lawn clippings, animal wastes, soil, sewage-treatment plants, septic systems, detergents, fertilizers, etc. Marketplace availability of Low and No phosphate fertilizers plays a role in reducing detrimental environmental impacts associated with phosphorus use.

2. Labelling Requirements and Analytical Tolerances

2.1 No phosphate specialty fertilizers for lawn and turf

A No Phosphate Fertilizer means a specialty fertilizer intended for application to lawns and turf that has a label grade of 0% phosphate, and does not contain more than 0.69% available phosphoric acid (P2O5) by weight.

Any lawn or turf fertilizer with an analytical result less than or equal to 0.69% available phosphoric acid (P2O5) by weight, may be represented on the label as a No Phosphate Fertilizer, or a similar designation. A lawn/turf fertilizer with an analytical result greater than or equal 0.70% available phosphoric acid (P2O5), will not be permitted to use the designation of a No Phosphate Fertilizer on the product label.

Section 21(3) of the Fertilizers Regulations states that: a grade designation shall be stated as a hyphenated numerical series and, in the case of mixed fertilizers other than customer-formula fertilizers, the numerals shall be in whole numbers only. Most specialty lawn and turf fertilizers meet the definition of a mixed fertilizer and therefore would be required to represent the nutrient grade in whole numbers on the label. However, regardless of whether the lawn or turf fertilizer meets the definition of a mixed or single ingredient fertilizer, it may only be represented as a No Phosphate Fertilizer if the label grade designation is 0% phosphate.

A No Phosphate Fertilizer should only be used on established lawns and turf (greater than 2 years old), and when soil phosphorus concentrations are high. A No Phosphate Fertilizer should not be used on newly seeded lawns, or recently laid sod. In addition, a No Phosphate Fertilizer should not be used on lawns or turf subjected to diseases or environmental stresses.

2.2 Low phosphate specialty fertilizers for lawn and turf

A Low Phosphate Fertilizer means any specialty fertilizer intended for application to lawns and turf that has a label grade between 1% and 3% phosphate, and contains a minimum of 0.70%, but not in excess of 3.3% available phosphoric acid (P2O5) by weight. Directions for single application rate of the product cannot exceed 0.125 kg available phosphoric acid (P2O5) per 100 m2 and directions for annual rate of application of the product cannot exceed 0.250 kg available phosphoric acid (P2O5) per 100 m2.

Any lawn or turf fertilizer with an analytical result greater than or equal to 0.70%, but less than 3.3% available phosphoric acid (P2O5) may bear representation as a Low Phosphate Fertilizer, or a similar designation, so long as a single rate of application does not exceed 0.125 kg available phosphoric acid (P2O5) per 100 m2, and an annual rate does not exceed 0.250 kg available phosphoric acid (P2O5) per 100 m2. As stated previously, Section 21(3) of the Fertilizers Regulations requires that mixed fertilizers must represent the grade in whole numbers. Below are the acceptable available phosphoric acid (P2O5) tolerances for Low Phosphate Fertilizers that meet the definition of a mixed fertilizer:

(i) If the Phosphate grade (and the guarantee) is 1%, the allowable available phosphoric acid (P2O5) analytical tolerance is between 0.70% and 1.69%.

(ii) If the Phosphate grade (and guarantee) is 2%, the allowable available phosphoric acid (P2O5) analytical tolerance is between 1.70% and 2.69%.

(iii) If the Phosphate grade (and guarantee) is 3%, the allowable available phosphoric acid (P2O5) analytical tolerance is between 2.70% and 3.3%.

The analytical tolerances are similar to tolerances in single ingredient lawn and turf fertilizers. The allowable permitted deficiency for a phosphate grade (or available phosphoric acid guarantee), in a single ingredient Low Phosphate lawn/turf fertilizer is 0.3%. The allowable permitted excess for a phosphate grade (or available phosphoric acid guarantee), in a single ingredient Low Phosphate lawn/turf fertilizer is 0.69%. Below is an example of an acceptable available phosphoric acid (P2O5) tolerance for a single ingredient Low Phosphate Fertilizer:

(iv) E.g. If the phosphate grade (and guarantee) is 1.5%, the allowable available phosphoric acid (P2O5) analytical tolerance is between 1.2% (0.3% deficiency) and 2.19% (0.69% excess).

A lawn or turf fertilizer with a grade greater than 3% phosphate, and/or an analytical result of greater than 3.3% available phosphoric acid (P2O5), and displays directions for a single application rate in excess of 0.125 kg per 100 m2, or directions for an annual rate in excess of 0.250 kg per 100 m2 available phosphoric acid (P2O5), will not be permitted to use the designation of a Low Phosphate Fertilizer on the product label.

A Low Phosphate Fertilizer should only be used on established lawns and turf (greater than 2 years old), and when soil phosphorus concentrations are high. A Low Phosphate Fertilizer should not be used on newly seeded lawns, or recently laid sod.

3. Regulatory Authority and Enforcement

3.1 Regulatory Authority

Any label representation of a fertilizer product as either a No Phosphate or Low Phosphate; fertilizer that is inconsistent with the aforementioned policy and tolerances would be deemed to be a contravention of Sections 19 (2) (a) and (b) of the Fertilizers Regulations:

(2) A label referred to in subsection (1) shall not have printed thereon (a) any incorrect or misleading information or mark; or (b) a brand or name that would tend to deceive or mislead a purchaser with respect to the composition or utility of the product to which the label relates.

3.2 Enforcement Action

The use of Low Phosphate or No Phosphate terminology is only permissible on specialty lawn and turf fertilizer labels that meet the definition and tolerances described in this document. Companies representing fertilizer products as Low Phosphate or No Phosphate in a manner inconsistent with these requirements may be deemed to be in contravention of the Fertilizers Act and Regulations, and be subject to enforcement action(s).

4. Contact

Fertilizer Safety Section
c/o Pre-market Application Submissions Office (PASO)
Canadian Food Inspection Agency
59 Camelot Drive
Ottawa, ON K1A 0Y9
Canada
Phone: 1-855-212-7695
Fax: 613-773-7115
Email: paso-bpdpm@inspection.gc.ca

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