CFIA AIRS Chapter 31 Update: Two New HS Codes Now Require Fertilizer/Supplement Registration

What Changed

CFIA published Chapter 31 revisions June 4, 2026, adding a registration type to two HS codes under the end use “For fertilizer or supplement”:

• 3101.00.4040 – Fertilizer containing seaweed or seaweed extracts
• 3101.00.5020 – Insects excreta unsuitable for use other than as fertilizers (frass)

Both codes now trigger an AIRS hold at primary if the CAD doesn’t carry a valid AIRS registration number tied to the importer’s BN15. The trigger sits in the CBSA Assessment and Revenue Management (CARM) portal’s integrated OGD hand-off logic; if the registration field is blank or the number doesn’t match CFIA’s live registry, release stalls until the importer or broker submits proof of registration.

Why This Matters for Brokers Filing CADs

Pre-CARM, CFIA holds were often cleared after the fact through email exchanges and broker follow-up. Under CARM, the integrated OGD workflow flags the shipment at the CAD submission stage. If the registration number is missing, the CAD doesn’t clear the portal’s validation gate, and the container sits at primary until CFIA closes the loop.

For seaweed-based fertilizer (3101.00.4040), most Canadian importers already know they’re in scope. The product has been regulated under the Fertilizers Act for years, and the eight- or ten-digit HS classification has historically signaled CFIA oversight. The new AIRS integration simply makes the registration number a hard field in the CAD.

Insect frass (3101.00.5020) is the newer case. Frass is the excreta and shed exoskeletons of farmed insects, typically black soldier fly or mealworm, sold as organic fertilizer or soil amendment. The product line has grown fast in the last three years, driven by vertical farming and cannabis cultivation suppliers. Many importers classified frass under generic headings in Chapter 31 without realizing the end-use registration requirement. This update closes that gap.

How to File the CAD

If your client imports either product, confirm the AIRS registration number before you file. The registration is issued by CFIA under the Fertilizers Act and ties to the importer’s BN15. The number format is typically a prefix + seven digits; you’ll enter it in the CARM portal’s “OGD Requirements” section of the CAD under the CFIA/AIRS field.

If the importer doesn’t have a registration, they need to apply through CFIA’s online portal. Turnaround used to be three to five business days; under the current backlog it’s running closer to ten. Plan accordingly if the shipment is already en route.

One trap: NRI (Non-Resident Importer) structures. If your client is using an NRI setup, the AIRS registration must be held by the Canadian party acting as importer of record. We see this blow up regularly when the U.S. principal holds the registration but the CAD lists the Canadian NRI entity as importer. CFIA won’t accept a cross-border registration mismatch, and the hold sits until the importer of record files a new application or restructures the entry.

End-Use Declaration

Both codes specify the end use “For fertilizer or supplement.” If your client is importing seaweed extract or insect frass for a different purpose (e.g., animal feed, industrial processing, research), the correct classification may sit elsewhere in the tariff, and the AIRS registration requirement may not apply. But if the commercial invoice, product literature, or labeling describes the product as fertilizer or soil amendment, expect CBSA to enforce the end-use requirement.

We’ve seen CBSA challenge end-use declarations on Chapter 31 products three times in the last six months, all triggered by mismatches between the declared HS code and the product marketing copy on the shipper’s website. If the importer is claiming a non-fertilizer use to avoid registration, make sure the documentation supports it before the CAD goes in.

What Happens If You File Without the Registration

The CAD won’t clear primary. CBSA’s system triggers an automatic CFIA referral, and the shipment holds until CFIA releases it. In practice, that means the container or pallet sits in our Montreal sufferance warehouse or another bonded facility, accruing storage and dwell fees, until the importer produces the registration number and CFIA manually closes the hold.

Typical timeline: two to five business days if the importer already has the registration and just forgot to provide it; ten to fifteen business days if they need to apply. Add weekend and holiday lag if the shipment arrives Thursday or Friday.

Storage cost at most Montreal-area bonded warehouses runs CAD 10 to CAD 18 per pallet per day, depending on the facility and the product’s handling requirements. A five-day hold on a 20-pallet load costs CAD 500 to CAD 1,800 in fees the importer didn’t budget for.

HS Classification Check

If you’re not sure whether your client’s product falls under 3101.00.4040 or 3101.00.5020, now is the time to confirm. Both codes sit at the ten-digit level, which means they’re Canada-specific extensions of the six-digit HS heading 31.01 (animal or vegetable fertilizers). The seaweed code covers any fertilizer containing seaweed or seaweed extracts as a material ingredient. The frass code covers insect excreta unsuitable for any purpose other than fertilizer.

If the product is a blend or a multi-ingredient formulation, the classification depends on the essential character test and the GIR (General Rules for the Interpretation of the Harmonized System). We run classification reviews on Chapter 31 products monthly, and the frass cases are the trickiest because the shipper’s documentation often omits the insect species or the processing method.

What to Do Now

Pull your active client list and flag anyone importing seaweed-based fertilizer or insect frass. Confirm the AIRS registration number is on file and matches the BN15 you’re using as importer of record on the CAD. If the client doesn’t have a registration, point them to CFIA’s application portal and build in lead time for the approval cycle.

If you’re filing CADs on either product this week, double-check the OGD field before submission. A missing registration number will cost your client a week of storage fees and a frustrated email chain.

We’ve updated our brokerage SOPs to flag both HS codes in the pre-file checklist. If you’re seeing AIRS holds pile up on Chapter 31 entries and want a second set of eyes on the classification or the registration workflow, get in touch.

Source: CSCB