Thank you so much for having me. Today we're talking about Bill C-368.
I am an importer of Chinese medicine. I'm also the founder of the Canadian College of Traditional Chinese Medicine. I have a master's in Chinese and integrative medicine. I'm also a Harvard medical educator. In non-profit, I set the standard at the Standards Council of Canada for TC 215 and TC 249 in Chinese medicine.
What we're looking at today is a regulatory mismatch for natural health products—putting them into a drug model and into Vanessa's Law, and treating food items and herb items as pharmaceutical items, which they are not. Do you have the package I sent out on food safety in Chinese medicine? If you go to see a Chinese medicine practitioner with kidney problems, they might prescribe you kelp or seaweed. If you have lung problems, they'll prescribe cinnamon, ginger, onions, etc. These are the natural health products we are using.
In Ontario, there are 2,700 Chinese medicine practitioners and acupuncturists. In Quebec, there are about 1,000. In B.C., there are 2,000. If you move down through the slides, out of these practitioners in Ontario, 65% are female. On direct job impact, the Job Bank of Canada record for 2021 shows that there are 66,000 Chinese medicine and acupuncturist natural practitioners in Canada. On indirect job impact, we have herbal farmers in Canada. There are over 2,000 individuals under the Good Agricultural Collection Practice. In Saskatchewan alone, there are 30,000 acres. In Ontario, there are about 150 ginseng growers. We are the purchasers and users of these natural health products, so all of those farmers would be out of business if we didn't support them.
We need something tailor-designed for natural health products. Right now, what we have works. It's going to affect us greatly if we don't pass Bill C-368.
Under the 60,000 practitioners, most patients are women, seniors and minorities. Most of us have hundreds, if not thousands, of patients. All of these patients would be affected without access to natural health products.
If you move down, there's the proposed amended fee. These are some of the companies we're looking at. Most of these companies annually renew. It's very common for us to have around 1,000 licences. We don't use all of the licences simultaneously—only if we need them. We need the licence to have access to herbs. For upkeep, you're looking at $130,000 to $200,000 annually just to keep the licence. That's not including the application fee, which is another $100,000 to $200,000.
This means that most households, especially lower-income households, would not have access. It would push us, as importers, into the black market. To avoid the $100,000 to $200,000 fee, people will sell online. They would not apply. That means the food items we want to have health claims for.... We're trying to do the right thing. We're going to be forced to sell them as food items, and we're going to say, “It has no effect.” All these practitioners would not have health claims on the items they're prescribing.
On the next slide, you'll see the example of Jia Wei Xiao Yao Wan. It's a pretty standard formula. Right now, on the market in Canada, it's about $9 or $10. With the proposed fee, we're looking at close to a $50 to $100 increase per product, because we use a lot of these licences. To keep those licences, we're going to look at $50, plus the $10. It would make it hard for people to purchase and use these products.
The purpose of natural health products is so food items and herbs that we're prescribing, as practitioners, have a health claim. It's not so drug items can escape responsibility as a drug. I saw previous experts talking about nicotine. I totally agree with them. Nicotine is highly addictive, and in a lot of countries—Australia, Japan and Thailand—it is considered a drug. They have a separate regulation, like our tobacco act in Canada. We use it to protect our public. A natural health product is not an escape to avoid the necessary law.
We also talked about evidence-based medicine. We want to have that in natural medicine, too. We hope to have grants and research funding, which we don't have. However, adding an additional law—Vanessa's Law—to this would only push us to the black market, to the other side of the border. We're going to have to sell from the U.S. where these $10,000 to $100,000 regulation fees are not realistic, and we're going to have to sell from other countries to Canada where people can have access from illegal markets, avoiding these costs.
Thank you so much.