Certainly.
Good morning, everyone, and thank you for the opportunity to be here.
My name is Helen Long, and I am here in my capacity as the President of the Canadian Health Food Association.
Our organization is the national voice of the natural health industry. We have over 1,000 members from coast to coast, including manufacturers, retailers, wholesalers, distributers, and importers. The vast majority of those would be small and medium-sized businesses. They contribute over $7 billion to Canada's GDP through the sale of organic foods and natural health products.
Over the years, our association and the industry as a whole have taken important steps to improve the quality and range of products available to Canadians to support their healthy lifestyle. We've also shown leadership in encouraging compliance with more effective processes and standards at Health Canada, especially with the introduction of the natural health products regulations. Those regulations, most recently updated in 2008, were developed with extensive public consultation and study by Health Canada. Canada is viewed around the world as a global leader in the regulation of these products.
The most important component of these regulations is the pre-market approval process overseen by Health Canada. Its role in reviewing product applications ensures that products coming to market in Canada are safe, effective, and high quality, while also respecting the low-risk nature of natural health products as compared to pharmaceutical drugs. This information is important for the committee, if for no other reason than to understand how far we've come in quite a short time.
The distinction between NHPs and drugs was initially drawn under the leadership of then-health minister Allan Rock during the Chrétien government's time in power. Later, under Prime Minister Martin, parliamentary committees upheld this view, and under the most recent Conservative government, the regulations were reviewed and affirmed. This is an example of the excellent work done by parliamentarians to help Canadians, 77% of whom take NHPs, to access high-quality products.
For the coming budget, CHFA is calling on the government to take the following steps to ensure that Canadians continue to have access to these safe, effective, and high-quality natural health food products.
First, we recommend that Canada maintain the current de minimis threshold of $200 for goods being imported to Canada. The only groups that support an increase in the de minimis level are those that have an interest in sending Canadian consumer dollars out of our country while diminishing the tax base and disproportionately hurting Canada's smallest niche businesses.
Second, we encourage the government to explore options to provide preferential tax treatment for NHPs. Research shows that Canadians who find themselves in poor health require approximately $10,000 more per year in health care costs, compared to someone in good health. If a mechanism can be put in place where consumers have cost-effective access to preventive measures, including not only natural health products but other things, it is possible to change lifestyles, leading to better health overall. We believe Canadians will benefit substantially from NHPs being given preferential tax treatment, to encourage them to focus more on proactive health care measures.
Third, the Canadian Food Inspection Agency and Health Canada are currently working to modernize Canada's food labelling system under each of their respective acts. CHFA supports this work, as it will provide more and better information for consumers who are seeking to make healthier choices. We are, however, concerned that the required labelling changes will affect every single food label in the country, requiring producers and vendors to incur an immense cost. We ask that the process be harmonized so that the coming into force of the regulations occurs at the same time, to allow producers to reflect both sets of changes in their labels at once. This approach would be good for consumers, while also respecting the operational requirements of businesses nationwide.
Last—and most important, since the beginning of September—our industry is asking the committee to consider the negative impact that Health Canada's proposed self-care framework will have on the millions of Canadians who use natural health products and the thousands of Canadians employed by businesses that produce and sell them. Health Canada is proposing changes that would include an entire class of products that would go directly to market without pre-market approval, which is a change we cannot and will not support. The system we have in place now works. Let's not fix something that isn't broken.
We are very concerned that this proposal, and the continuation of the personal importation loophole, will jeopardize the reputation of the NHP industry for companies that play by the rules, while leaving Canadian consumers confused and questioning the credibility of the NHP sector.
Thank you again for the opportunity to speak in your time today.