Good day, ladies and gentlemen. Thank you.
The Canadian Health Food Association, or CHFA, is Canada's largest national trade association dedicated to the natural products industry.
CHFA is Canada’s largest national trade association dedicated to the natural health and organic products industry. Our 1,300 members represent the entire supply chain, including growers, manufacturers, retailers, wholesalers, distributors, and importers. Our members are involved in a variety of subsectors, such as vitamin and mineral supplements; herbal products; homeopathics; sports nutrition products; and natural and organic foods, fibres, and health and beauty aids. Natural health products have become increasingly popular as Canadians look for better ways to manage their health. In fact, over 75% of Canadians purchase natural health products. The Canadian NHP industry is currently valued at over $2.5 billion.
I would like to speak immediately today about the challenges our industry currently faces as well as the recommendations we propose as the voice of the natural products industry.
Specifically, our members have serious concerns around the current interpretation and implementation of the natural health products regulations. The 1998 Standing Committee on Health's report, Natural Health Products: A New Vision, laid the groundwork for the creation of a unique framework for natural health products founded on the acknowledgement that natural health products were of low risk and were neither foods nor drugs. The government is to be commended for its timely implementation of some of the 53 recommendations from this report.
In 2004, the natural health products regulations came into force. However, the regulatory requirement to license some 50,000 products and over 800 domestic sites has led to serious disruptions in the marketplace, including decreased product innovation, loss of products, inability to advertise, and consumer confusion. In addition, the current instability of the marketplace is driving business away from Canada and restricting product choice.
The government is to be acknowledged and recognized for providing additional funds to the natural health products directorate--NHPD--in its most recent budget to assist in dealing with this enormous backlog. However, it will be important for these funds to be used in a manner that will enable the backlog of submissions to be reviewed and licensed in the most expeditious manner possible.
The CHFA is very concerned that with the increasing pressure on NHPD to deal with the backlog, an inordinate number of submissions are being rejected due to administrative issues that we believe could be easily solved with direct contact between the directorate and the applicant.
Further, changing and increasingly rigid policy interpretation continues to frustrate applicants and drive businesses away from Canada. As an industry dedicated to the health and well-being of Canadians, we want to ensure that Canadians can continue to rely on safe and effective natural health products. This can only be realized if the directorate has a clear direction on how to move forward, has the support of the department and stakeholders, and is provided with the necessary resources and expertise.
Furthermore, on the issue of the 53 recommendations, despite the implementation of many of these over the past 10 years, there are still many recommendations that our members have identified as being inconsistent with the standing committee's intent in the way they are interpreted and/or applied by the directorate. In CHFA's brief we discuss a number of recommendations that have not been addressed. I will highlight only one, the one that we believe is most critical to our industry.
Specifically, it is important that the government consider creating a separate category for natural health products, which is the very first recommendation in the 1998 health committee's report. Currently, natural health products are considered to be a subset of drugs; this is clearly contradictory to the findings of the Standing Committee on Health, which stated that NHPs are neither food nor drugs.
We believe this legislative classification places an unrealistic burden on an industry that manufactures, imports, distributes, or sells products that are of low risk. If the establishment of a separate category for natural health products is in legislation, we believe the low-risk nature of these products will be appropriately reflected in the implementation and interpretation of the NHP regulations.
Thank you very much.
Merci beaucoup.