Feed Regulatory Renewal Consolidated Modernized Framework Proposal – November 2015
Annex 2: Proposed Labelling Requirements

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Component Current Requirement Proposed
Manufacturer Name & Address In the case of a feed not required to be registered, the name and address of the person who manufactured the feed or caused it to be manufactured

Name and address of manufacturer or who caused it to be manufactured (which includes allowing a head office contact) for feeds that are not registered.

Additional names and addresses such as those of the head office for the company, importer or distributor may also be included on the label on a voluntary basis.

Registrant Name & Address, Reg'n # In the case of a feed required to be registered, the name and address of the registrant For feeds that are registered, name and address of the registrant.
May add the manufacturer information on a voluntary basis.
Feed Name

The name of the feed in accordance with section 32

The name of a feed shall be appropriate for the intended use of the feed and shall not be misleading.

The feed name should reflect the following components:

Purpose or Feed Type
The purpose for which a feed is intended shall be identified as part of the feed name. The purpose may be a complete feed, a supplement, a premix, antioxidant, colour, etc.

Species or Category of Intended Livestock
The species or category of livestock for which the product is intended must be identified on the label as part of the feed name. If a product is intended for all species of livestock it does not need to indicate a species or it may indicate "for all livestock" .

Brand Name The brand of the feed, if any The brand of the feed, if any
Net Amount The net amount expressed as the number of units in a package, in the case of a package of feed containing individual feeding forms, or
Expressed as the mass or volume in the package or shipment, in the case of any other package or bulk shipment of feed
The net amount expressed as the number of units in a package, in the case of a package of feed containing individual feeding forms, or
Expressed as the mass or volume in the package or shipment, in the case of any other package or bulk shipment of feed
Registration # The registration number, where applicable Must have registration number, can be anywhere on label provided it's "conspicuous, legible, indelible, etc"
Guaranteed Analysis

An accurate statement of the guaranteed analysis in respect of the feed (see Table 3 for required guarantees)

The label of a feed shall not show a guarantee for a nutrient that is not required to be guaranteed unless..
…the amount of the nutrient guaranteed is such that when used as directed the complete diet including the feed will supply at least the minimum generally accepted requirements for that nutrient for the intended class of livestock and…
…the guarantee is approved in writing by the Director as conveying useful information to the feed purchaser.

It is proposed that the same approach continue to be taken and we will further examine the requirements for specific feed types.
Will examine Table 3 and make any needed changes.
Directions for Use Subject to section 27(3) [any directions for use required to be shown on a label may refer to an insert…if insert is enclosed within the package…] directions for use in sufficient detail to permit safe and effective use of the feed for its intended purpose by users with no special knowledge of the purpose and use of the feed.

Require directions for use for all feeds.

Guidance (outside of regulations) to be provided to allow a purpose statement or a "for use in livestock feeds" as sufficient directions for use.

List of Ingredients In the case of a feed that is required to comply with the guarantees set out in item 7 of Table 3 of Schedule I, the name of each ingredient in the feed
In the case of a feed other than a feed referred to [above] the name of each ingredient in the feed or the statement "a list of ingredients used in this feed may be obtained from the manufacturer of registrant."
All feeds require the complete list of ingredients for that feed on the label
Collective terms allowed.

Manufacturer/registrant must supply actual list of ingredients by their Sched IV names upon request.
Lot # An identification code, in the case of a micro-premix feed or a feed designed to replace whole milk in the ration of the livestock.

All feeds must have a lot number.

For further guidance/discussion: Must be clearly identifiable as a lot #. Manufacturer must be able to confirm when and where the product was manufactured.

Medicated Feeds:
  • Name and amount of medicating ingredient
  • Claim(s)
  • Caution Statement(s)
  • Warning Statement(s)

If the feed is a medicated feed, other than a veterinary prescription:

The name and actual amount of the medicating ingredient present in the feed, in accordance with the CMIB, in direct association with the feed name

The claim or claims applicable with the kind of medicating ingredient present in the feed, the level of MI in the feed and the type of livestock for which the feed is intended, as set out in the CMIB

Every caution statement in respect of the MI present in the feed that is set out in the CMIB under or next to the heading, in bold print "caution" . Each statement shall be clearly separated from any other caution statement and any other information on the label.

Every warning statement in respect of the MI present in the feed that is set out in the CMIB under or next to the heading, in bold print "warning" . Every warning statement shall be clearly separated from any other warning statement and any other information shown on the label.

If the feed is a medicated feed, other than a veterinary prescription:

The name and actual amount of the medicating ingredient present in the feed, in accordance with the CMIB, in direct association with the feed name

The claim or claims applicable with the kind of medicating ingredient present in the feed, the level of MI in the feed and the type of livestock for which the feed is intended, as set out in the CMIB

Every caution statement in respect of the MI present in the feed that is set out in the CMIB under or next to the heading, in bold print "caution" . Each statement shall be clearly separated from any other caution statement and any other information on the label.

Every warning statement in respect of the MI present in the feed that is set out in the CMIB under or next to the heading, in bold print "warning" . Every warning statement shall be clearly separated from any other warning statement and any other information shown on the label.

Form If the feed contains a medicating ingredient and is in a form other than a mash, the particular form of the feed If the feed contains a medicating ingredient and is in a form other than a mash, the particular form of the feed
Claims A label shall not contain…any claim for a mixed feed or any ingredient in the feed unless evidence has been assessed or evaluated and found to support the claim.
…any claim for a single ingredient feed unless evidence has been assessed or evaluated and found to support the claim.
It is proposed that the basic approach for claims should be that labels should not contain claims other than those which are truthful and verifiable. Also proposed that not all products with label claims will require premarket assessment. Proposed development of a list of permissible claims which would not trigger a requirement for registration.
Claim would still need to be assessed and approved can be done via policy not registration.
Units of Measurement All units of measurement shown on a label of a feed shall be expressed in metric measure only in accordance with the Weights and Measures Act.

Only metric, except allow net weight to appear in imperial.

For multi-jurisdictional label create a specific exemption which would allow other units to meet the requirements of those other markets.

PM statement If the feed contains pm as defined in HoA, the following statement written legibly, indelibly and conspicuously:
"Feeding this product to cattle…"
If the feed contains pm as defined in HoA, the following statement written legibly, indelibly and conspicuously:
"Feeding this product to cattle…"
Consultant formula In the case of a consultant formula feed, the name and address of the specific purchaser for whom the feed was manufactured. Based on changes to what requires registration this class of feed should not be required
SIF In addition to the labelling requirements prescribed in subsection (1), a single ingredient feed shall be labelled in accordance with the labelling requirements set out for that feed in Schedule IV. In addition to the labelling requirements prescribed in subsection (1), a single ingredient feed shall be labelled in accordance with the labelling requirements set out for that feed in Schedule IV.
Container (place of manufacture) Where any reference, direct or indirect, is made on a label or container to the place of manufacture of the label or container and not to the place of manufacture of the feed, the reference shall be accompanied by an additional statement indicating that the place of manufacture refers only to the label or container. 26(9) Where any reference, direct or indirect, is made on a label or container to the place of manufacture of the label or container and not to the place of manufacture of the feed, the reference shall be accompanied by an additional statement indicating that the place of manufacture refers only to the label or container. 26(9)
Place of manufacture Where a feed that is manufactured or produced and labelled in a country other than Canada has applied to it a label that shows the identity and principal place of business of the person in Canada for whom the feed was manufactured or produced for resale, the identity and principal place of business of that person shall be preceded by the words "imported by" or "imported for", unless the geographic origin of the product is stated on the label. Where a feed that is manufactured or produced and labelled in a country other than Canada has applied to it a label that shows the identity and principal place of business of the person in Canada for whom the feed was manufactured or produced for resale, the identity and principal place of business of that person shall be preceded by the words "imported by" or "imported for", unless the geographic origin of the product is stated on the label.
Biological testing claim No statement shall be made on the label of a feed indicating that such feed has been biologically tested unless
The feed has been biologically tested using scientifically acceptable test methodology
The results of such tests supports any claim contained in the statement or any claim implied by the statement
Evidence that such tests have been made and the results of such tests have been supplied to the Director for assessment or evaluation.
No statement shall be made on the label of a feed indicating that such feed has been biologically tested unless
The feed has been biologically tested using scientifically acceptable test methodology
The results of such tests supports any claim contained in the statement or any claim implied by the statement
Evidence that such tests have been made and the results of such tests have been supplied to the Director for assessment or evaluation.

Should work with the Permissible Claims concept (e.g. Director's approval is via adding claim to the list).
Language Any information required to be shown on the label of a feed shall be printed conspicuously, legibly and indelibly in English or French or both languages. Proposed that any label information which impacts health and safety will be required to be present in both French and English (to meet Official Languages requirements).
See "international labels" document for full details on allowing other languages on labels.
Allow the geographical exemption but require that the manufacturer provide the label information in the language of choice.
Location of information Subject to subsection (3) and unless otherwise authorized by the Director, any information that is required to be shown on the label shall appear on the main panel of the package label or where the package contains less than 5 kg on the surface of the package.
(3) Any directions for use required to be shown on a label may refer to an insert containing detailed directions for use if such an insert in enclosed within the package that bears the label.
Use "principal display surface" definition from CPLR. Feed regs will specify which info is required in principal display surface and which may be listed elsewhere
Caution and warning statements Currently as part of medicated feed requirements, feed ban, or ingredient labelling. Same as current plus…
Labels would also require any additional cautions or warnings which convey useful information to the purchaser.
Proposed that when a feed is manufactured using an ingredient or mixed feed which has a caution or warning statement on its label, or for which there is a maximum inclusion rate of an ingredient, this relevant information must be transferred onto the label for the new feed product.
Expiry/Best Before dates No current requirement. Allowed or required on some registered feeds and verified via registration Proposed that for feeds which do not require a "best before" or "expiry" date, one may be indicated on the label on a voluntary basis.
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