Health Canada

As previously reported, Health Canada amended its proposed fees for Natural Health Products, substantially reducing the costs to industry. However, stakeholders, including the CAND, continue to have concerns about increased costs for industry and health care professionals and the resultant loss of products that NDs must have access to, in order to treat their patients safely and effectively.

In response to requests from stakeholders, Health Canada extended the time to submit comment on the revised proposal to May 25, 2024. In the period of time leading up to the submission deadline, the CAND met with Senior Staff in the Health Ministers office on two occasions, as well as a number of MP’s, to reiterate our concerns and provide more detail on the increased cost of NHPs and products that have already been discontinued by professional line companies in anticipation of the cost recovery fees. The meetings were productive and we expect, following Health Canada’s review of all submissions, that there will be further consultation with stakeholders.

The CAND’s submission has been acknowledged by Health Canada and is posted on the CAND.ca Members Portal by clicking this link, NHP Submission.

In response to changes made to the Food and Drugs Act in the fall budget, a private members bill,Bill C – 368, which would repeal the changes and remove Natural Health Products from the definition of a therapeutic product, passed second reading in the House of Commons and has been referred to the Standing Committee on Health (HESA). Now that it is before the Committee, stakeholders will have an opportunity to appear as witnesses to outline their ongoing concerns and answer questions from Committee Members. The CAND is engaged with Committee staff with respect to appearing before the Committee, and has been advised by Committee members that they support the CAND’s attendance to give evidence.

We will continue to update members on this important issue moving forward.

Please reach out to our Director of Government Relations, Shawn O’Reilly at [email protected] with any questions.

In May of last year, Health Canada launched a consultation on proposed cost recovery fees for Natural Health Products. As members are aware, the CAND and other stakeholders in the natural health sector, were extremely concerned that the costs proposed would result in the loss of companies and products available on the Canadian market.  The CAND launched an extensive campaign to advise Health Canada, the NNHPD, the Health Minister and Members of Parliament about our concerns. Our collective voices were heard and we thank all our members for their impactful engagement.

As a result of the overwhelming response received, the NNHPD went back to the drawing board and on March 27, 2024 presented a revised Cost Recovery Proposal to stakeholders. The revisions contain significant reductions in all proposed fees. Whereas the estimated costs of the initial proposal were $100.8 Million, the revised proposal reduces the overall costs to $51.1 Million and includes lower fees for pre-market evaluation (50% reduction), site licenses (75% reduction) and right to sell (50% reduction), as well as improved discounts for small businesses. In addition to lower fees in all categories, a 7 year phased in approach is proposed and anticipated to begin December 1, 2025.

At the conclusion of the presentation, stakeholders were advised that they would have until April 25, 2024 to provide comment on the revised proposal. The CAND, along with a number of other key stakeholders, filed written objection to the short consultation period, requesting it be extended to a full 90 days. In response the NNHPD has extended the time to submit comment for an additional 30 days to May 25, 2024.

While we are pleased to see the reduced costs in this latest proposal, the CAND and others, are still concerned about the impact of increased costs on industry and health care providers as well as the lack of forward movement on the Self Care Framework, launched in 2016 and still not completed. The Framework will result in changes to the NHP regulations with respect to the classification of products and the health claims they will be able to make.

It is important to note that while some form of cost recovery will be implemented, the impact it will have on product costs and availability is yet to be determined. However, regardless of what is implemented, NDs will not lose the ability to practice or provide patients with the information they need about the natural health products they are taking as part of a treatment plan.

The revisions can be viewed here:

Revisions to the Proposed Fees for Natural Health Products.

The CAND will be preparing a submission on the revised Cost Recovery Proposal and continue to push the NNHPD to complete the Self Care Framework. We will advise members of further developments.

The proposal can be read here: Proposed Fees for Natural Health Products.

What is the CAND doing?

The CAND has filed a submission in response to the consultation outlining our concerns and the impact the proposed fees will have on the naturopathic profession, naturopathic small businesses and naturopathic patients. The submission can be read here: CAND NHP Consultation Submission Letter

We continue our outreach to our government contacts, Members of Parliament and the Minister of Health, arranging and conducting meetings to outline our concerns and ask for their support in requesting the government reconsider its proposal or, suspend it until completion of the Self – Care Framework.

As well, we are still in regular contact with the CHFA and other leading industry associations, supporting the actions being taken by the CHFA to inform Members of Parliament and the public about the impact the proposed fees will have on the natural products industry.

What can NDs and patients do?

The CAND has prepared letter templates that NDs and patients can use in drafting letters to send to their Members of Parliament (MP). The templates, as well as a link to where people can find their MP, can be found below.

Template Letter for NDs – Option 1

Template Letter for NDs – Option 2