Protect natural health products

by Joseph Roberts

A relatively new government directorate focused on natural health products is about to develop regulations that will have very serious consequences on the type and availability of natural health products (NHPs).
We need to become aware of the current NHP context and the HPFB “Cost Recovery Initiative” process. We must also consider the consequences before any more regulations or guidelines are imposed. Who does it serve? How does NHP cost recovery hurt natural health products? How will our freedom to choose health products be affected, because they certainly will if we do nothing?
On April 23, 2007, a handful of people from the natural products industry met to clarify the intentions of the new Natural Product Directorate in “taxing” natural products through the process of “cost recovery.” There will be “side effects” which could include death to a number of small to medium-sized companies.
More people need to meet and discuss this issue. We don’t just represent the stakeholder; we are the stakeholders: from growers to manufactures to distributors to retailers and the citizens that use natural healthy products in Canada.
It seems that the interests behind the push in Canada parallels the bigger push in the US and other wealthy countries where major profits are made by drug companies. Initially, some well-intentioned people supported NHP’s promises of safer, more standardized products. We may be missing the bigger game and how we are being played.
The pattern seems the same in most countries. A threat to public health and safety is hyped around natural products or remedies. This manufactures the perception of a huge problem that the government must then step in to fix. Government wades in. They then tax the fix and the additional costs are passed down to the consumer.
Common Ground is hosting a public meeting to discuss this issue on Tuesday May 29 at Chai Tea House, 3243 West Broadway (upstairs). Call Jamie at 604-733-2215 to RSVP. Seating is limited.

Note: This meeting follows meetings in Ottawa on May 1 and the HPFB Cost Recovery Initiative’s May 15 deadline, so there will be lots to discuss.

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This is the letter the Canadian Health Food Association emailed April 24:

Dear CHFA Member,

The government of Canada is moving quickly towards its objective of implementing cost recovery for the natural health products industry. The proposed fee schedule will have serious implications for all CHFA members dealing in natural health products.

Members will see costs of doing business increase, product margins decrease, product innovation decline, product quality compromised, and access to products reduced. It is important that EVERY CHFA member respond to the government’s questionnaire and Business Impact Test (BIT).

The following links will take you to the background documents
(http://www.hc-sc.gc.ca/dhp-mps/consultation/cri-irc/index_e.html) ,  the BIT (http://www.hc-sc.gc.ca/dhp-mps/consultation/cri-irc/business_impact_entreprise_e.html) and the Questions for Discussion (http://www.hc-sc.gc.ca/dhp-mps/consultation/cri-irc/hpfb-dgpsa_co-reco_7_e.html#1).

The completed BIT and answers to the questions MUST be submitted to the government by MAY 15, 2007.

Suggested responses, compiled by the CHFA, to the BIT and the questionnaire will be sent to all members before the end of the week.

It is imperative that every member take the time to complete the Business Impact test and the answer the questions before May 15, 2007.

Please watch your email / fax for additional information.

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Health Canada set to dismantle the natural health product industry

by Ben Banky

This is an urgent message to all Canadians who use natural health products, such as vitamins and supplements. Your future access to many of these products is in danger of being severely curtailed and possibly eliminated within the next two years. Sound unbelievable? Unfortunately, it is all too true. Health Canada is proposing to implement manufacturers’ fees that will result in skyrocketing retail prices.
In mid-April, Health Canada sent a proposal for “cost recovery” to the natural health industry asking for industry feedback. Very few industry stakeholders actually received the proposal directly and no consumers or retailers were notified or invited to participate.
Essentially, this new proposal sets out the federal government’s plan to recoup the costs of administering the licencing of natural health products (NHPs). For those unfamiliar with NHPs, they are a third category recently set up by the government to differentiate these products from either food or drugs. The program was originally intended to ensure public safety by setting standards of manufacturing and ingredient claims.
While few in this industry would argue against these goals, there are many that would go out of business overnight if they were forced to pay the proposed fees, and those able to survive would have to severely limit the variety of products they manufacture and focus solely on the ones that make the most money. Furthermore, the amount of money the government would collect from this initiative goes far beyond the current costs of the NHP program.
For Canadian consumers, it will mean far fewer products on store shelves, dramatic price increases and a decline in both product innovation and product quality. At a time when we are looking for ways to cut healthcare costs and focus on preventative medicine, this seems a very bad step in exactly the wrong direction.
Health Canada has given the industry only three weeks to respond to its questionnaire. The deadline is May 15. In an effort to raise awareness and build support, the Canadian Health Food Association sent out urgent e-mails to all its membership asking for a response by the deadline. The larger the response, the better chance we have of preventing the government from railroading this through.
The purpose of this article is to let you know what is going on backstage. On May 1, industry stakeholders will meet with the federal government to discuss the proposed fees. By May 15, they will start tabulating the results of the industry questionnaire. This will be followed by a review process and a formal complaint process.
Somewhere in this process, we will know if the government is willing to look at fee mitigation or alternative strategies that will not so severely burden this critically important industry. Hopefully, the answer is yes. Barring that, it will be time for our citizenry to stand up and once again have its voice heard.
I urge you to visit Health Canada’s website (www.hc-sc.gc.ca) and learn more. I urge you to contact your Member of Parliament and make her or him aware of what is being proposed and its potential ramifications. Finally, I urge you to be ready very soon to fight for your continued access to safe natural health products at reasonable prices. To find out more, visit www.chfa.ca and www.hc-sc.gc.ca. (See CHFA’s letter to members.)
Future issues of Common Ground will feature updates on this important issue.

Ben Banky is the co-owner of TallGrass, a Vancouver-based importer and wholesale distributor of natural health products. He can be reached at info@tallgrass.biz

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Natural Health Directorate - should we trust it?

by Joan Henderson

More than six years ago, the government informed the natural products industry that the public wanted natural supplements to be regulated to ensure their safety and efficacy. While many participants expressed concern about the proposed regulations, the majority of industry representatives got on board, hoping to instill confidence in consumers.
Communication from the government about the changes, with both the public and people in the industry, has, at times, been sketchy or non-existent. Initially, industry and the public were assured that the Natural Health Directorate (the department formed to handle the development and monitoring of these new regulations) was overseeing a new third category. The industry was assured that there would now be three categories: food, natural health products and drugs. Two years later, it leaked, or should we say seeped out, that there was no third category. Natural health products had now become a sub-category of drugs. For many, it was a warning sign. The majority of the public and natural food retailers and many others in the industry were not consulted about this change and most were unaware that it had happened.
As part of the new regulations, the Natural Health Directorate mandated that all natural health products had to have health claims on their labels, linking the product to a disease or health-related condition. The industry was assured that this would be an easy process. After all, natural products were not potentially harmful like drugs, and the information would assist people in understanding how to use the product.
The industry was assured that the health claims on herbal supplements’ labels – supplements that had been in use for over 50 years – did not need to be proven as they had historical and traditional use to support their safety. However, all anyone has to do is talk to anyone trying to get a traditional herbal remedy on the market today. The fact is that what the government initially promised and what has actually transpired are very different. The standards for submissions have changed several times, and, in some cases, the regulations are so complex that a whole new industry has developed to “advise” and “assist” companies on how to submit the applications to ensure their acceptance. Further, applications are being submitted and resubmitted at great cost to the manufacturers. Some applications for NPNs (natural health product numbers) submitted more than two years ago have not yet been processed, and applications are not being processed in the order they were submitted. Not one NPN has been granted for herbal combinations. Very few of the staff dealing with these NPN submissions at the directorate has previous training or expertise in the natural supplement or herbal industries. What this means is that it is costing money and someone has to pay.
In early April, the government notified the natural products that it is now proposing a cost recovery program for its natural health directorate and the services it supposedly provides. Fees for product submissions, annual product registrations and other fees, such as access to information fees, will have serious ramifications for consumers and manufacturers alike. Some small, innovative companies may have to close their doors as they will not be able to afford the proposed start-up and annual product fees. The companies that are able to survive will have to pass these costs on to the retailer who, if they wish to stay in business, will pass them on to the consumer.
The majority of prescription drugs are paid for through extended medical plans. Natural supplements are not. Many Canadians are seriously trying to take ownership of their health and the health of their families. This proposed government cost recovery program will limit the type and the efficacy of the natural supplements available on the market. Natural product innovation will slow down. Some products available now will not be as effective due to simplified formulas or the use of less expensive ingredients. Others will be unaffordable for the average consumer, especially for seniors on limited incomes and those with growing families. Many people will be forced to turn to prescription drugs for financial reasons, thus causing physical and environmental damage. Oh? Could there be an agenda?
Consumers, get involved. Call your MPs and write to the federal government. Sign petitions in health food stores. Tell your friends. Speak up before you can no longer afford to buy natural health products and supplements.