Thank you for the opportunity to comment on that.
The current reliance order, which we expect to be published in part II of the Canada Gazette this summer, is a good first step. Is it the end of the road for improving that, and a silver bullet? Absolutely not.
The reality of the Canadian market is that we are small. Every additional regulatory cost or burden that contributes to that makes it difficult.
When you're talking about relatively specialized pharmaceuticals, like something you use to treat urinary incontinence in female spayed dogs, you're talking about a fairly minor use in the overall market; therefore, the cost of registration for that kind of product.... It's not just that, because there's also the cost of labelling specifically for the Canadian market. There are also all the logistical costs of actually bringing something in that we're not necessarily manufacturing here.
I think the reliance order is a good first step, because we don't then have to reinvent the wheel of what other trusted jurisdictions have done on that. However, we also need to look at all the other Canadian-specific requirements around labelling and product management. Currently, we still require paper product monographs with every drug. Other jurisdictions have moved to a QR code-based thing, where you basically scan the QR code and don't have to print out a paper version of the monograph in French, but you have the option of going to a French version of it. It reduces packaging, the costs and some of the issues that make it difficult to bring products here.
The other side of that is that once a product is here, there are also ongoing costs related to maintaining it on the market here. There are drug establishment licence costs for every piece of the manufacturing chain that goes into producing that specific drug.
A regulatory package came into force in 2019 that increased the requirements for veterinary active pharmaceutical ingredients. That has led directly and largely to the loss of products that are important to dairy farmers, for example. You've lost your injectable vitamins. You've lost a lot of your supplements that have been around for decades. That's partially because producers are having a hard time finding manufacturing sites that will meet new Canadian manufacturing requirements for components of those injectable vitamins and supplements, and it becomes unsustainable in the long term to keep them on the Canadian market.
Therefore, I also think we need to look at the cost of maintaining products here, and all of the cumulative regulatory burdens that create a problem with respect to the availability of veterinary medicines across the board.