Storage of grain on the ground, in bunker storage, or other storage alternatives

Trade memo number

2026-05

Date issued

2026-08-01

The purpose of this memo is to remind licensees that paragraph 16(a) of the Canada Grain Regulations requires that the operator of a licensed elevator store all grain received in an elevator building.

The Canadian Grain Commission can, in most circumstances, exempt a licensed elevator from the regulation prohibiting storage of grain outside of an elevator building. To be considered for such an exemption, elevators must submit a written request to the Canadian Grain Commission, advising:

• how the grain will be stored — on the ground, in bunker storage, in grain bags, in railcars, or other method
  • bunker storage is defined as a structure that is part of the premises of a licensed elevator, but not part of the elevator itself
  • to be considered bunker storage, the structure must be fully enclosed and have a concrete, asphalt, or other prepared base^{Footnote 1}, rigid and self-supporting sidewalls, door(s), and a cover
  • all non-concrete or non-asphalt bases for bunker storage that have not previously been approved by the Canadian Grain Commission must be inspected and approved by the Canadian Grain Commission prior to an exemption being granted
• the kind and quantity of grain to be stored outside of the elevator building
• the date that grain to be stored outside the elevator building will be received and the date that this same grain will be discharged

The responsibilities of elevator operators are the same for grain stored outside of the elevator building and for grain stored in the elevator building. Upon delivery of the grain to be stored outside of the elevator building, a primary elevator receipt, grain receipt, or cash purchase ticket must be issued to the party delivering the grain. Depending on how the grain is being stored and/or the type of structure being used, security requirements may be impacted.

Once all grain that was stored outside of the elevator building is shipped, the elevator operator must advise the Canadian Grain Commission in writing.