What The August 10, 2023 Deadline Is And Isn’t

We have been receiving a lot of questions and comments in regard to the consultation period that closes this week, on August 10 at 11:59pm ET, so we want to clear up some misconceptions.

The purpose of this consultation period is to collect feedback regarding the implementation of a new manufacturer fee proposal for natural health products (NHPs). These proposed fees are part of Health Canada’s non-negotiable plan to impose the Self-Care Framework which will harmonize regulation of natural health products and over-the-counter chemical drugs. Given Health Canada’s position is that the Self-Care Framework is non-negotiable, this consultation period comes across somewhat disingenuous.

Understand that the Notice to comment makes it clear that fees will be imposed, regardless of comments. Fees will be “refined”.

For full details on this, see Shawn Buckley’s Discussion Paper – Part 3 – Cost Recovery, pages 13-24

It’s imperative to understand that this consultation period does NOT relate to:

  • the Repeal of sections 500-504 of Bill C-47
  • the application of Vanessa’s Law to natural health products
  • increased fines (up to $5 million per day) and powers of Health Canada same as chemical drugs
  • stopping the Self-Care Framework refer to page 4 of the Discussion Paper for more details), such as:
  • claims will be restricted to minor conditions, for which a person would not seek the advice of a licenced health care practitioner
  • traditional use evidence will no longer be allowed to support all claims, and impose the same standards of evidence for chemical drugs on natural health products
  • it will become functionally illegal to treat anything but the most minor of conditions with natural products

We encourage you to make your thoughts on the proposed new fee guidelines known to our Government before the end of this consultation period.

Understand that this is just one part of a much bigger picture of the over-regulation of natural health products under the Self-Care Framework already being implemented.

There is much more to do after August 10, 2023.

Our work does not end on August 10, 2023.

If you need inspiration to provide your feedback on the consultation, some of NHPPA’s biggest concerns around the proposed new fee guidelines, include:

  • The fees being imposed will drive more small and many medium Natural Health Product (“NHP”) businesses and practitioners out of business.
  • The new fees will fund new permanent inspection/regulatory programs that will dramatically increase the regulatory burdens on NHP businesses and practitioners.
  • We will lose natural health products, natural health companies, and eventually natural health practitioners.
  • Natural health product prices will increase, and already are, removing products from people in our communities who rely on natural health products for their health conditions, and will no longer be able to afford them.