On Moday, January 1, 2024, Lucas Anderson, Vice President of the CAOA, wrote an email to the Natural and Non-prescription Health Products Directorate Consultation, Health Canada, Government of Canada, regarding the concerns of new health product legislation.

On February 7, 2024, Lucas received a reply. 

We have provided the correspondence below for our members to review and to give direction to those who want to take action.

Good day,

My name is Lucas Anderson, I am the current Vice President of the Canadian Alliance of Aromatherapy (CAOA), an organization that strives to set high standards for those practicing aromatherapy professionally in Canada.  It has been brought to our attention that Health Canada is making changes to the Natural Health Products legislation that may negatively impact the practices of our members. 

As Aromatherapy is not a Regulated Health Profession yet, it often seems that there aren’t many opportunities for us to get involved in the setting of regulations, or find it too late to get involved, which affects our members’ small businesses.  I am mostly reaching out to find out if there is any way in which the CAOA can get more involved and be included in conversations about future policy changes that might affect our members.  With the new changes being made to the Natural Health Product legislation, we welcome HC to invite us to the table to discuss the planned changes.  Thus creating a better discussion with those involved in their use and how the legislation could be made better to protect Canadians, but also protect the practitioners who help Canadians through the use of aromatic plants and compounds, Natural Health Products.  

Please let me know if there is any way to become registered as a stakeholder, or as an organization whose members share a significant role in the use of natural health products so that we can have a voice in any future, or current changes to the NHP regulations.  We would greatly appreciate that.  Thank you, cheers.

Dear Mr. Anderson, 

Thank you for your correspondence regarding the regulation of natural health products (NHPs).  

Health Canada recognizes that NHPs are important to Canadians to help support and maintain their health and is committed to supporting access to NHPs that are safe and of high quality.  

While NHPs are generally lower risk products, they are not without risk.  

In 2021, the Commissioner of the Environment and Sustainable Development completed an audit of Health Canada’s NHP program and found both strengths and areas for improvement. Health Canada committed to undertaking a number of activities to improve the safety of these products.  

This is not about limiting the production of NHPs or consumers’ access to them. This is about making sure the products Canadians use are safe and of high quality.  

In July 2022, Health Canada introduced new requirements to make NHP labels easier for Canadians to read and understand, to address concerns about small font sizes and missing or unclear information.  

In June 2023, the Government passed legislation allowing Health Canada to take more action if a serious risk to health is identified with an NHP. For example, this legislation allows Health Canada to order a recall of a product or add warnings to labels to support safe use, if necessary, which it couldn’t do before. These new authorities would only be used if a serious risk to health is identified and if a company refuses to cooperate with voluntary measures.  

Now, Health Canada is proposing fees for industry to create an even safer marketplace for consumers and begin to recoup a portion of the costs of services it provides to industry. Presently, NHPs are the only line of health products where the regulatory activities are fully funded by Canadian taxpayers.

Health Canada understands that many NHP companies are small businesses that provide jobs for people in Canada. That is why the Department is considering measures to mitigate the impact of the new fees. This includes fee reductions for small businesses ranging between 25% to 50%, and a full waiver of pre-market evaluation fees for small businesses marketing their first product. 

The Department is actively reviewing thousands of comments received on its fee proposal, including the fee reduction for small businesses, as part of an open and transparent consultation process. Health Canada is considering how best to adjust its proposed approach to address the concerns raised in order to protect Canadians and support businesses. 

We recommend that you register with Health Canada’s Consultation and Stakeholder Information Management System (CSIMS) to be informed and consulted on health topics. For more information about the registry, please consult our FAQs.

Everyone is eligible to register and you may unsubscribe at any time. You can register as a member of an organization, as an individual or as both. Your information will be collected and kept safe in accordance with the federal Privacy Act. Once your registration has been verified, you will receive a user name and password in your email within 5 business days.

If you have any questions or concerns please contact CSIMS-External@hc-sc.gc.ca.

Thank you for your interest in the regulation of NHPs and we hope this information is helpful. For more information on our recent initiatives, please visit: https://www.canada.ca/en/health-canada/services/drugs-health-products/natural-non-prescription/regulation.html

Natural and Non-prescription Health Products Directorate ConsultationHealth Canada, Government of Canada

nnhpd.consultation-dpsnso@hc-sc.gc.ca 

Direction des Produits de santé naturels et sans ordonnance consultation

Santé Canada, Gouvernement du Canada

nnhpd.consultation-dpsnso@hc-sc.gc.ca

Lucas has registered the CAOA as a member of Canada’s Consultation and Stakeholder Information Management System (CSIMS).

We encourage all CAOA Members to do the same. 

Please follow this link to register.