CFIA updates fertilizer and supplement registration guidance under the Fertilizers Act

The Canadian Food Inspection Agency (CFIA) has released an updated version of its Guide to Submitting Applications for Registration Under the Fertilizers Act, reflecting a significant modernization of the registration submission process and aligning the Guide more closely with the MyCFIA digital workflow. This update brings both structural enhancements and important content revisions that applicants should carefully review when preparing new fertilizer or supplement submissions.

Improved access to CFIA guidance and clearer ISCI procedures

A key improvement is the integration of embedded links throughout the Guide, connecting users directly to relevant CFIA guidance documents and webpages. This added interactivity streamlines navigation and ensures applicants can easily access supplementary regulatory information. The updated Guide also provides expanded instructions for submitting an Ingredient Source Change Inquiry (ISCI), along with a direct reference to CFIA’s T-4-122 service delivery standards, where current ISCI procedures and timelines are detailed.

Updated terminology and formatting improvements

Several terminology and format updates are included as well. The CFIA has officially renamed “Me-too” applications as “Private label” submissions, better reflecting the nature and intent of these applications. The Guide now features expandable and collapsible sections to improve readability, as well as a new template table (Table 2) outlining CFIA’s preferred format for submitting input materials information.

Revised CFIA safety data requirements, including PFOS/PFAS testing

Substantive changes have also been made to the safety data requirements for Level I, II, and III assessments. Level II materials now include amino acids, crustaceans, and worm castings, while biochar has been removed. Level III materials have been expanded to include vitamins, as well as nitrification and urease inhibitors. Additionally, the updated Guide introduces a new section addressing PFOS/PFAS testing requirements for biosolid based products, reflecting increased attention to emerging contaminants.

Expanded requirements for microbial and gene‑edited ingredients

Microbial ingredient requirements have been broadened to incorporate considerations for CRISPR and other modern gene editing technologies. The CFIA now emphasizes the need for off target analysis, and applicants will find updated checklists, expanded reference materials, and clearer expectations for demonstrating microbial safety.

Additional precautionary labelling requirements

Finally, the Guide highlights new precautionary statements that may be required on product labels in addition to those outlined in T-4-130, recognizing scenarios where supplemental risk communication may be necessary.

What these CFIA updates mean for fertilizer and supplement applicants

Taken together, these updates represent a meaningful evolution of the CFIA’s regulatory framework and reinforce the importance of staying current with submission expectations. Companies preparing applications, whether for new formulations, private label products, or amended registrations, should carefully review the updated Guide to ensure completeness, accuracy, and compliance.

How Sagentia Regulatory supports CFIA submissions

Applying the updated Guide in practice will require judgement, particularly where requirements have evolved, new risk areas have been introduced, or existing registrations may need to be reassessed.

Sagentia Regulatory (formerly TSG Consulting) works with companies to translate regulatory updates into clear, proportionate submission strategies, helping ensure applications are structured and supported in line with CFIA’s current expectations.

This includes helping applicants:

• Understand how the updated Guide affects new, amended and private label registrations
• Review current or planned product formulations to confirm registration readiness
• Understand Level I, II, or III data expectations under the updated Guide
• Navigate Ingredient Source Change Inquiries (ISCI) and associated requirements
• Prepare submission packages aligned with CFIA’s preferred formats
• Address requirements for microbial, gene edited, or biosolid based ingredients
• Assess label compliance, including newly noted precautionary statements

If you are preparing a submission or reviewing existing registrations, our team can help you apply the updated guidance with clarity and confidence.