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Labelling guidance for the proposed Feeds Regulations, 2022

The information in this document is based on requirements set out in the proposed Feeds Regulations, 2022 (the "regulations"). The information is intended to help regulated parties understand the requirements within the regulations once they come into force. The proposed requirements are subject to change as the regulatory process advances through its various stages. In the interim, current laws applicable to livestock feed in Canada continue to apply.

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Summary of changes

Under the proposed Feeds Regulations, 2022, amendments have been made to the labelling requirements for feeds which would allow for greater flexibility and provide better information to purchasers.

All feeds must be labelled, and the label must not deceive or mislead the purchaser of the feed. Feed that is manufactured, sold, or imported must have a label attached to it or to the package containing the feed. If the feed is shipped in bulk, a label must be attached to it or the label information may appear on any document, including the invoice, shipping bill or statement of account delivered to the purchaser with the shipment. If a feed is intended for export, the only requirement is that the label clearly indicates that the feed is intended for export.

The proposed amendments will still require feed labels to have:

Furthermore, greater flexibility has been provided to reduce the regulatory burden on stakeholders while at the same time adapting to evolving changes within the feed industry.

The key updates to the labelling requirements include:

Labelling requirements

The table below provides a comparison of the basic information that is currently required to appear on feed labels under the Feeds Regulations, 1983, and what will be required under the proposed Feeds Regulations, 2022.

Comparison of current versus proposed feed labelling requirements
Content of the label Feeds Regulations, 1983 Feeds Regulations, 2022
Name of the feed Yes Yes
Name and address of the person who manufactured the feed, or caused it to manufactured or the registrant Yes Yes
Identification code (lot number) Yes, but only a requirement for micro-premixes and milk replacers Yes, requirement for all feeds
Net amount and units of measurement (expressed in metric units) Yes Yes
Guaranteed analysis statement Yes Yes
Directions for use Yes Yes
Feed registration number (if feed is registered) Yes Yes
Prohibited material (PM) statement (if feed contains or may contain PM) Yes Yes
Information set out in the Compendium of Medicating Ingredient Brochures (if feed contains medicating ingredients) Yes Yes
Information set out in the Compendium of Non-Feed Product Brochures (if feed contains one or more of these non-feed products) N/A Yes
Claims Yes, but registration required Yes - registration is not required if the claim is listed in the Tables of Permissible Claims for Feed Labels and the conditions for that claim have been met.
Additional label guarantees Yes, but registration required Yes - registration is not required if the optional guarantees are listed in the Tables of Nutrient Guarantees and Conditions for Feed Labels and the conditions for the optional guarantees have been met.
Other useful information (for example, caution and warning statements) Yes Yes

The requirements for individual feed labels will vary depending on the type of feed and the purpose that the feed is intended for. More detailed information on the labelling requirements can be found below and has been separated into those for mixed feeds and those for single ingredient feeds.

Mixed feeds

Feed name

The name of the feed must be suitable for the intended use of the feed and must not be misleading. The feed name must contain the purpose of the feed (for example, premix, supplement, anticaking agent, energy source, flavouring agent, etc.) and the intended livestock species (for example, swine) or class of livestock (for example, finisher swine, laying hens, lactating dairy cattle, etc.).

Mixed feeds must have a name that accurately reflects the composition of the feed. For example, feeds that are labelled as complete feeds must provide all of the daily nutrient requirements for the intended livestock species. In addition, the regulations specify that certain feeds must include the feed type (or purpose) as part of the name. Premixes, supplements and customer formula feeds must include their respective feed type in the name of the feed.

Directions for use

The directions for use should reflect how to use the mixed feed for its intended purpose. Directions for use need to be detailed enough to permit a purchaser with no special knowledge to use the mixed feed safely and appropriately.

For example, if a feed is a premix, the directions for use must indicate how the feed is to be further mixed. A supplement, on the other hand, must have directions for use that indicate how it is to be used in conjunction with other feeds.

Guaranteed analysis

The guaranteed analysis must reflect the purpose of the feed. The Tables of Nutrient Guarantees and Conditions for Feed Labels indicate which guarantees are required on a particular label based on the type of feed. It also provides a list of optional guarantees that may be added to the label if a company feels they are relevant. Nutrients that are supplied at significant amounts should be guaranteed on the label to allow the purchaser to make an informed decision. A mixed feed label should only include guarantees for a nutrient if the nutrient is present at a level that will provide nutrition to the livestock species or class of livestock it has been formulated for. Guaranteeing a nutrient that is present at a level that is nutritionally insignificant for a particular livestock species or class of livestock may provide misleading information and lead the purchaser to think they are buying a feed that is adequate and sufficient for a particular purpose when it may not be.

Unless otherwise stated on the feed label, the guaranteed analysis must be based on the feed as it is to be fed to livestock, and therefore the guaranteed analysis must take into account the maximum moisture content of the feed.

List of ingredients

For mixed feeds, the label must contain the name of each single ingredient feed used in the formulation of the mixed feed or the following statement: "A list of the ingredients used in this feed may be obtained from the manufacturer or registrant." However, if the feed is a registered mixed feed with a claim on the label that is not set out in the Tables of Permissible Claims for Feed Labels, the name of each single ingredient feed is required to appear on the feed label. In addition, some permissible claims may require the full list of ingredients on the label as a condition of that claim.

If the full list of ingredients is not included on the label, the regulations would require the manufacturer or registrant to provide the list within 3 business days of a written request.

Name and address

The label must include the name and address of the manufacturer of the mixed feed, the person who caused it to be manufactured or the registrant (that is, the person or company who has registered the feed). The name and address on the label can be the contact information for the head office, the sales or marketing department, a third party supplier, etc. It does not have to be the actual place where the feed was manufactured. This contact information will be the first point of contact by the purchaser or the Canadian Food Inspection Agency (CFIA) to follow up if there are questions about the feed.

Identification code

All feeds must have an identification code (lot number) on the label. Manufacturers are responsible for determining what they consider to be an individual lot for each of their products. The identification code is one of the key pieces of information required to ensure the traceability of mixed feeds. Lot numbers are already required on certain livestock feeds, and on all feeds considered animal food under the Health of Animals Regulations.

If a problem is found with a feed, the entire lot may be subject to enforcement actions.

Net amount

The feed label must accurately reflect the net amount. This must be expressed in metric units, but may also include other units of measurement, such as imperial units. In the case of a package of feed containing individual feeding forms it may be expressed as the number of units in the package and the weight of each unit.

Feed registration number

Feeds that are registered must clearly indicate the valid registration number.

Prohibited material (PM) statement

Feeds that contain or may contain prohibited material must include the following statement in both English and French on the label.

"Feeding this product to cattle, sheep, deer or other ruminants is illegal and is subject to fines or other punishment under the Health of Animals Act. / Il est interdit d'en nourrir les bœufs, moutons, cerfs et autres ruminants et des amendes ou autres peines sont prévues à cet égard par la Loi sur la santé des animaux."

Claims

Mixed feed labels may contain a claim as set out in the Tables of Permissible Claims for Feed Labels. Labels containing these permissible claims would not require registration provided all conditions associated with the claim have been met. Claims that do not appear in the Tables of Permissible Claims for Feed Labels may be made but will require that the mixed feed be registered.

Specific labelling requirements for certain mixed feed types

Medicated feed

For medicated feeds, the label must contain the information set out in the Compendium of Medicating Ingredient Brochures for each medicating ingredient in the feed. This information includes:

This product-specific labelling information is in addition to the information mentioned above under the section for mixed feeds.

Custom medicated feed

For custom medicated feeds (previously known as veterinary prescription feeds), the label must contain:

This product-specific labelling information is in addition to the information mentioned above under the section for mixed feeds.

Mixed feeds containing non-feed products

For mixed feeds containing non-feed products found in the Compendium of Non-Feed Product Brochures, the label must contain the information and conditions set out in the Compendium for each non-feed product included in the formulation. This information includes:

This product-specific labelling information is in addition to the information mentioned above under the section for mixed feeds.

Customer formula feed

If the customer formula feed does not contain medicating ingredients, the label must include:

In addition, the name and address of the manufacturer and the name of supplier of the formula used to manufacture the must be on the label. If the customer formula feed contains a non-feed product referred to in the Compendium of Non-Feed Product Brochures, information as set out in this Compendium must also be on the feed label.

If the customer formula feed does contain medicating ingredients, the label must include:

In addition, the name of supplier of the formula used to manufacture the feed must also be on the label. If the customer formula feed contains a non-feed product referred to in the Compendium of Non-Feed Product Brochures, information as set out in this Compendium must also be on the feed label.

A label is not required if a customer formula feed is manufactured by a feed manufacturer for feeding their own livestock.

Other labelling requirements for mixed feeds

In addition, if a mixed feed consists of a single ingredient feed which has caution and warning statements on its label, this information must be transferred onto the label for the mixed feed that has been manufactured using the single ingredient feed in its formulation.

Single ingredient feeds

Feed name

If the label is for a single ingredient feed, the feed name must include the ingredient name as listed in the Canadian Feed Ingredients Table, the general nutritional or functional classification, and the intended livestock species or class of livestock which the single ingredient feed is approved for.

Directions for use

The directions for use should reflect how to use the single ingredient feed for its intended purpose, as listed and categorized in Canadian Feed Ingredients Table. Directions for use need to be detailed enough to permit a purchaser with no special knowledge to use the single ingredient feed safely and appropriately. Any directions or restrictions on use as well as any caution and warning statements that are found in the ingredient description in the Canadian Feed Ingredients Table must be reflected on the label of the single ingredient feed.

Guaranteed analysis

For single ingredient feeds, the label must contain all of the required guarantees that are specified for that ingredient as indicated in the Canadian Feed Ingredients Table. Optional guarantees as set out in the Tables of Nutrient Guarantees and Conditions for Feed Labels may also be included on the label.

List of ingredients

In some situations, a list of ingredients may appear on a single ingredient feed label. This is the case if the definition of the single ingredient feed, as listed in the Canadian Feed Ingredients Table, indicates that non-nutritional ingredients such as carriers, antioxidants, pelleting aids, anticaking agents, etc. are to be indicated on the single ingredient feed label.

Name and address

The label must include the name and address of the manufacturer of the single ingredient feed, the person who caused it to be manufactured or the registrant (that is, the person or company who has registered the feed). The name and address on the label can be the contact information for the head office, the sales or marketing department, a third party supplier, etc. It does not have be the actual place where the feed was manufactured. This contact information will be the first point of contact by the purchaser or the CFIA to follow up if there are questions about the feed.

Identification code

All single ingredient feeds must have an identification code (lot number) on the label. Manufacturers are responsible for determining what they consider to be an individual lot for each of their products. The identification code is one of the key pieces of information required to ensure traceability of the single ingredient feed. Lot numbers are already required on certain livestock feeds, and on all feeds considered animal food under the Health of Animals Regulations.

If a problem is found with a feed, the entire lot may be subject to enforcement actions.

Net amount

The single ingredient feed label must accurately reflect the net amount. This must be expressed in metric units, but may also include other units of measurement, such as imperial units. In the case of a package of feed containing individual feeding forms it may be expressed as the number of units in the package and the weight of each unit.

Feed registration number

Single ingredient feeds that are registered must clearly indicate the valid registration number on the label.

Prohibited material (PM) statement

Single ingredient feeds that are or may contain prohibited material must include the following statement in both English and French on the label.

"Feeding this product to cattle, sheep, deer or other ruminants is illegal and is subject to fines or other punishment under the Health of Animals Act. / Il est interdit d'en nourrir les bœufs, moutons, cerfs et autres ruminants et des amendes ou autres peines sont prévues à cet égard par la Loi sur la santé des animaux."

This statement will also appear in the single ingredient feed description in the Canadian Feed Ingredients Table for those ingredients that require it.

Claims

Single ingredient feeds may contain a claim as set out in the single ingredient feed description of the Canadian Feed Ingredients Table or the Tables of Permissible Claims for Feed Labels. Any other claims require the single ingredient feed to be registered.

Other labelling requirements for single ingredient feeds

Any statements, including caution and warning statements, that have been specified for that single ingredient feed in the Canadian Feed Ingredients Table must appear on the label.

Mandatory bilingual labelling requirements for all feeds

The label for a feed (mixed feed or single ingredient feed) must be either in English or French or both. However, to satisfy the requirements of the Official Languages Act, health and safety information must now appear in both official languages. This includes:

To help regulated parties meet these bilingual labelling requirements, most statements that are required to be in both languages on a feed label will appear in the regulations, the Canadian Feed Ingredients Table, or the Compendium of Medicating Ingredient Brochures.

Imported feed

If any feed (mixed feed or single ingredient feed) is manufactured in a country other than Canada, the label must contain the geographical origin of the feed (for example, manufactured in the USA) or the phrase "imported by" or "imported for" followed by the name and address of the person in Canada for whom the feed was manufactured for resale.

Feed for export

Feeds (mixed feed or single ingredient feed) intended for export do not need to meet domestic Canadian labelling requirements. These feeds must be clearly labelled with "export" or "exportation" and may contain the labelling information required by the importing country.

Benefits of proper labelling

Updating the feed labelling requirements provides additional flexibilities when compared to the current Feeds Regulations, while maintaining the same level of safety and consumer protection. Labels play an important role in the safe and proper use of feeds. Proper labelling allows a purchaser and user of a feed to distinguish one feed product from another, it allows them to make an informed decision and it provides information on what the feed is and how it is to be used. Feed products which are not labelled, or do not have the appropriate information on the label, may be unintentionally used in a manner that is not safe and results in animal health, human health or environmental concerns.

Labels that provide accurate representation and information on the use of a feed can help to minimize risks. This information includes providing caution and warning statements which indicate a specific risk, directions for use which indicate how to safely use the feed and a guaranteed analysis and list of ingredients which allow the purchaser to know what is in the feed, and therefore, use it safely and properly.

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