by Dr. Iva Lloyd, ND
- In Canada, regulation for natural health products (NHPs) came into effect in 2004. Naturopathic doctors (NDs) were active in lobbying for the regulation of NHPs.
- The regulation of NHPs falls under Health Canada's Natural and Non-prescription Health Products Directorate (NNHPD)
- The first Director of the NNHPD was a naturopathic doctor.
- Canada has one of the highest levels of regulation for NHPs ensuring that the products sold are safe and that they contain what is on the label.
The Cost-Recovery Proposal
- Hefty fees including site licenses, pre-market evaluation of products and fees for each product being sold.
- The number of NHPs available to consumers would be reduced.
- A number of NHP manufacturers would likely leave the Canadian marketplace.
- The result is that the cost of NHPs would increase for consumers.
Concerns with the Cost-Recovery Proposal
- It appears that the implementation for NHPs is based on the cost-recovery process for drugs and medical devices. There hasn't been adequate consultation on the impact of cost-recovery on the NHP industry and how the NHP industry differs from drugs and medical devices.
- The cost proposed are significantly higher than the NHP industry can sustain, especially as the majority of NHP manufacturers are small to medium-sized companies.
- The time-frame for phasing in the cost-recovery is only two years which is way too short.
- As NHPs are not covered by third-party insurance, and are generally paid for out-of-pocket by consumers, the impact of cost-recovery on consumers needs to be considered.
- The government receives taxes on NHPs and it does not appear that the taxes are going towards reducing the cost-recovery fees for the industry.
- The cost-recovery Proposal is coming at the same time as the new Labelling Requirements for NHPs which is already imposing a significant cost on the industry - and hence increasing costs for consumers.
- Bottom line, the cost recovery proposal is too aggressive and will impact the NHP industry and consumers negatively.
Protecting Our Access to NHPs
- The Canadian Association of Naturopathic Doctors, which represents the interest of NDs, is preparing a submission addressing the impact of the current Proposal to NDs and their patients.
- Naturopathic Doctors have been requested by the CAND to write letters to their Member of Parliament.
- The Canadian Health Food Association (CHFA) which represents the interests of health foods stores is also in discussions with Health Canada and has a grassroots initiative called Save Our Supplements Campaign.
- Many manufacturers will be addressing the specific impacts that the cost-recovery proposal would have on their business and their ability to delivery NHPs at a reasonable cost to consumers.
- Write a letter to your Member of Parliament before August 10th. A letter template that the CAND has created is at the bottom of my patient handouts page.
- Participate in the CHFA Save Our Supplements Campaign.