Pesticide Labeling in Canada

New guidelines allow the OMRI seal under certain conditions.

By Sara Nienaber, Application Supervisor

(June 6, 2017) A regulatory directive released by the Health Canada Pest Management Regulatory Agency (PMRA) now permits the OMRI seal (or other logos that communicate that a product is compliant with the Canada Organic Regime) for use in advertising pesticide products, if accompanied by specific label language.    

Historically, logos or language indicating that a product can be used in organic production, including use of the OMRI seal, have not been permitted for use on pesticide products marketed in Canada. A memo issued by PMRA in 2011 specifically prohibited the use of the OMRI seal for pesticide products sold in Canada. This memo was archived in 2013, the same year that OMRI began reviewing products to the Canada Organic Regime (COR) standards. Though all OMRI Canada listed products are issued a certificate and included on the OMRI Canada Products List^©, the inability to use the OMRI seal was a concern for OMRI Listed® companies who wanted to market their products to organic growers in Canada. 

During PMRA’s public comment period, OMRI submitted comments to emphasize the need for pesticide suppliers to be able to use the OMRI seal. In November 2016, PMRA published regulatory directive DIR2016-01 Guidelines for the Advertising of Pest Control Products. This document replaces previous information included in DIR96-02 Environmental Label Claims and Advertising of Pest Control Products and DIR99-02 Advertising Pest Control Products.

The Guidelines address a number of different advertising claims that may apply to pesticide products. This document emphasizes that the “basic goal of restrictions on the advertising of pest control products is to prevent false or misleading claims about the health, safety, environmental impact, or value of these products” because such claims may result in use of the products in a manner that causes harm. One of the general guiding principles of this document is that pesticide producers should be able to “substantiate all claims with reliable evidence” in order to avoid misleading statements.

Regarding organic claims on pesticide product labels, the Guidelines specify that the term “organic,” as defined by the Canada Organic Regime, applies only to the outputs of organic production (food and fiber, for example), but not to input materials (including pest control products). As such, pesticide labels cannot advertise that a product is “organic,” “biologique” or “organique.” The only exception to this rule is that the term “biologique” would be permissible in cases when the word is intended to mean “biological” and not “organic.” 

However, PMRA does recognize the need for producers of pesticide products to promote their products to the organic market. Therefore, pest control products that meet the criteria for use in organic production as outlined in Organic Production Systems—Permitted Substances Lists, CAN/CGSB-32.311 may use the following statement to advertise their product:

This pest control product contains only substances that appear on the Organic Production Systems Permitted Substances Lists and may be suitable for use in organic agriculture; please consult your authorized organic Certification Body for further information.   

In order to use this statement, pesticide producers must ensure that the label does not suggest that a product is certified organic or otherwise “certified.” This is because the term certified organic is associated with organic outputs, as outlined above, and is not suitable for input materials. Accordingly, the Canada Organic Logo must not be associated with a pesticide product, since this would imply organic certification of this material. 

The Guidelines specify that the above statement “may be accompanied by a logo that indicates a product’s potential suitability for use in organic agriculture, as determined by a recognized assessor.” OMRI is ISO 17065 accredited for input review under both the COR and NOP standards. 

Suppliers who have pesticide products that are OMRI Listed to the Canadian standards may use the OMRI Canada seal in direct association with listed products only if the seal is always accompanied by the above statement.

OMRI’s review is specific to confirming organic compliance of input products and does not evaluate legal compliance of these materials. It is the responsibility of each OMRI Listed company to ensure that they comply with all applicable regulations for listed products. Please contact PMRA with any questions related to revising pesticide labels for products registered in Canada.

As stated in the labeling statement from PMRA, certified organic producers should work with their Certification Body to ensure that all input products used are compliant for use in organic production and approved for inclusion in their operation’s organic plan. 

This article was originally published in the Summer 2017 edition of the OMRI Materials Review newsletter.