Saturday, July 1, 2023

Protecting Your Access to Natural Health Products

 by Dr. Iva Lloyd, ND

In May of this year, Health Canada announced a consultation on proposed cost-recovery fees for natural health products (NHPs). Currently the costs associated with the regulation and oversight of NHPs has been predominantly publicly funded. The cost-recovery proposal is intended to bring NHPs in line with the fees charged for other health products such as drugs and medical devices.

Read: Health Canada's Proposed Fees

Historical Viewpoint

  • 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

Health Canada's cost-recovery proposal, as it stands, would have a significant negative impact on the natural health products sector and would result in:
  • 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

The idea that the Canadian NHP industry would engage in cost-recovery was introduced a number of years ago.  Generally speaking, implementing cost-recovery is an indication that the industry has matured and is more self-sustaining, yet there are major concerns with the current cost-recovery proposal including:
  • 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

There are a number of initiatives underway requesting that Health Canada revise and delay the cost-recovery proposal. For example:
  •  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.
What you can do to ensure your ongoing access to NHPs

The voice of civil society is very powerful. It has been almost thirty years since the naturopathic profession has requested that patients join them in protecting their rights to the products and services that they choose to maintain their health.  What we ask you to do is:
Together we can ensure that Canadians continues to enjoy access to wide range of NHPs that are safe, affordable and effective.