Testing, Grading, Tagging, Labelling and Advertising of Plant Pest Tolerance Management (PPTM) Varietal Blends of Corn Seed
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The Plant Biosafety Office (PBO) of the Canadian Food Inspection Agency (CFIA) has authorized the unconfined environmental release of several plants with novel traits conferring insect tolerance in corn. These authorizations require implementation of Insect Resistance Management (IRM) plans which specify the planting of a refuge, non-tolerant corn variety in close proximity to the tolerant variety, among other conditions.
Typically, seed of the insect-tolerant variety is purchased and planted separately from the refuge variety. However, the PBO has authorized certain products to be released with a blended refuge, in which seed of both the insect-tolerant variety and the refuge variety may be packaged and planted as a single, blended product. The ratios of the insect-tolerant and refuge varieties in these plant pest tolerance management (PPTM) varietal blends are specified as a condition of the authorization granted by the PBO. The availability of these PPTM varietal blends is expected to simplify producer implementation of IRM requirements.
The PBO authorization further requires that the germination level of the refuge component of the blend should be such that the refuge is maintained in the field at the percentage specified in the authorization.
PPTM varietal blends of corn must be appropriately tested, graded, and tagged when offered for sale in the marketplace. The industry advisory Sampling and Testing Requirements for Seed Imported into or Sold in Canada outlines the general sampling and testing requirements for corn and other crop kinds. The following information is intended to clarify the more specific requirements for testing, grading, tagging, labelling and advertising of PPTM varietal blends of corn.
Seed establishments blending the seed must maintain complete records of the blending of the varieties to enable tracing back and tracking forward of the seed in the marketplace. The blending procedures and related record keeping must be included in the quality management system manuals or procedures of the establishment.
It is recommended that the component varieties be sampled and tested separately, prior to blending, in order to provide clear evidence of the quality of the seed lots that make up the blend.
The seed testing laboratory may be requested to test samples of the individual components of a PPTM varietal blend of corn or a single sample of the pre-blended seed. The samples should be tested as received.
When samples of each component are submitted separately, before blending, the tests should be conducted separately, and a report of analysis issued for each sample. The grader should combine the results in order to establish the grade of the final blend.
Samples of pre-blended seed are tested in the same way as single varieties of corn (i.e., as a single sample) and a single test report is issued. The seed testing laboratory is not required to determine the percentage germination of the individual components or percentages of the component varieties in the blend.
If the germination of the refuge variety is below the grade standard it is not recommended to average this with a higher germination percentage in the dominant, insect tolerant variety in order to meet the grade standards. There is a risk that the standing crop will not meet the PBO requirement for a specified minimum percentage of the refuge variety in the standing crop if the germination of the refuge variety is too low.
The CFIA recommends that, especially in the case of treated seed and seed carried over from a previous year, the germination tests be repeated prior to sale to verify that the germination of the seed still meets the labelled grade and the conditions of the PBO authorization. Seed should be re-graded, re-labelled and/or re-blended if the seed lot no longer meets the germination standard of the original labelled grade or the conditions of the PBO authorization.
A PPTM varietal blend of corn is graded in the same way as seed of a single variety of corn. Table VI (corn and sunflower hybrids) of Schedule I to the Seeds Regulations (the Regulations) applies.
- If the final blended product, when offered for sale in Canada, meets the Canadian purity and germination standards in Table VI, then a Canada pedigreed grade name may be applied to the blended product.
- Where the two components individually meet the Canadian purity and germination standards in Table VI, then the Canada pedigreed grade name may be applied to the blended product.
As per section 8 of the Regulations, seed of field corn must be of pedigreed status to be sold in Canada. Therefore, all seed of hybrid corn offered for sale in Canada (including PPTM varietal blends) must be of pedigreed status and bear an official seed tag.
Canadian domestic official seed tags (CFIA/ACIA 0031 - Certified) or labels (CFIA/ACIA 0041 - Certified) must be applied to PPTM varietal blends of corn offered for sale in Canada.
- The official domestic tags must indicate the name of the two varieties (e.g., Corn AA/Corn BB).
- The space intended for the crop certificate number on the official domestic tag must indicate the two digit seed year designation of the seed year in which the blend was made, followed by the word Blend (e.g., 13-Blend).
- A unique lot number must be created for the blend and appear on the official tag. It must be possible to link the lot number with the blend sheet or a pedigreed seed declaration during a general inspection by the CFIA.
- It is not permitted to indicate the percentages of the component varieties on the Canadian official seed tag.
A. Seed certified by a foreign official seed certifying agency
Imported Certified status PPTM varietal blends of corn may be sold in Canada with tags issued or approved by another official certifying agency that indicate that the seed is of pedigreed status. In addition:
- if the seed is graded in Canada, then the Canada pedigreed grade name must appear on a document that accompanies each sale of the seed and bears the name of the person selling the seed; and
- if the seed is imported into Canada already labelled with a Canada pedigreed grade name, then the Canada pedigreed grade name and the number of the accredited grader must appear on a label attached to or printed directly on each package of seed.
B. Seed imported and then re-labelled with Canadian Interagency tags
Where one or more of the components of the blend are imported, and the seed is blended, packaged, or re-packaged, in Canada after import, the seed must bear the official Interagency Certified seed tag (CFIA/ACIA 5627 – Interagency Certified). The following information must appear on the Interagency tag:
- the names of the two varieties (e.g., Corn AA/Corn BB);
- the unique lot number of the blend, either in the field for the reference number or the lot number, or both; and
- for hybrid corn seed imported from the US, the name(s) of the official state certifying agency(s).
It is not permitted to indicate the percentages of the component varieties on the Interagency Certified tag; however, this information may appear on the foreign official tag or company tag/label.
Advertising and Labelling
PPTM varietal blends of corn may be advertised using the name of the dominant variety without mention of the name of the refuge variety, but both variety names must appear on the official seed tag.
In advertising or labelling, if a suffix such as VB (varietal blend) is appended to the variety name, then this should not be presented as part of the variety name. For example, advertising using Variety Max VB is not permitted, however, Blend Max VB or simply Max VB is permitted. Where the seed is referred to as a variety, only the actual variety name(s) should be indicated.
Use of Brand Names
Paragraph 15(2)(c) of the Regulations prohibits the use of any brand name or mark that might be construed or perceived as the name of a variety. The brand name must be followed by the word Brand, or TM, or ®.
For example: if a company has a brand DMX and a variety registered as 1234, then the company may advertise the variety using one of: DMXTM 1234 or DMX® 1234 or DMX Brand 1234. It is not acceptable to advertise the variety as: DMX 1234 or DMX1234.
For more information contact:
Field Crops and Inputs Division
Plant Health and Biosecurity Directorate
Policy and Programs Branch
Canadian Food Inspection Agency
59 Camelot Drive
Ottawa, Ontario K1A 0Y9
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