Health Committee on Oct. 5th, 2026

[The Chair, Liberal, Sukh Dhaliwal]

I call this meeting to order.

Welcome to meeting number 36 of the House of Commons Standing Committee on Health.

I would like to remind participants of the following points. Please wait until I recognize you by name before you speak. For members in the room, if you wish to speak, please raise your hand. As a reminder, all comments should be addressed through the chair. The clerk and I will manage the speaking order as best we can. We appreciate your patience and understanding in this regard.

On behalf of the committee, I would like to welcome the honourable witnesses. I have one request of you. If you can, keep an eye on the honourable member asking the question. If the honourable member raises their hand, I would like you to stop and give the floor to the honourable member. Cross-talking is very hard on the interpreters and also on the other participants. If you can maintain that decorum, please, we should be fine.

Pursuant to the order of reference adopted by the House on Tuesday, March 10, 2026, the committee shall commence its study of Bill C-224, an act to amend the Food and Drugs Act regarding natural health products.

I would now like to welcome our witnesses for the first hour.

From the Canadian Health Food Association, we have Ms. Sonia Parmar, vice-president, government relations and regulatory affairs; and Ms. Laura Gomez, lawyer and legal counsel.

From Food, Health and Consumer Products of Canada, we have Ms. Roberta Kramchynsky, vice-president of consumer health products and regulatory affairs.

From the Natural Health Product Protection Association, we have Shawn Buckley, president.

Welcome to all. I would like to remind witnesses that committee members may ask questions in either French or English. If you require interpretation, please take a moment now to prepare your earpiece and select the channel that you need.

Each organization has five minutes for opening remarks.

I will give the floor to Ms. Sonia Parmar for five minutes.

Please go ahead.

[Sonia Parmar, Vice President, Government Relations and Regulatory Affairs, Canadian Health Food Association]

Thank you.

I'm here on behalf of the Canadian Health Food Association, Canada's largest trade association representing over 1,300 businesses across the natural, organic and wellness sector.

How natural health products are defined in law shapes how they're regulated and whether that regulation is proportionate to risk. In 2023, the budget implementation act brought natural health products into the definition of therapeutic products, which included pharmaceutical drugs and medical devices, extending provisions of Vanessa's Law to this sector. This significant change came through an omnibus budget bill, without the focused consultation and scrutiny it deserved.

Natural health products are not drugs. Natural health products differ fundamentally from pharmaceuticals. This sector is built largely on small and medium-sized businesses often making multi-ingredient products without pharmaceutical patent protection or pharmaceutical margins. They do not have the ability to make disease treatment claims and, most importantly, these are products for the maintenance of good health, which means they can be safely taken daily.

Canada has long recognized those differences through a distinct regulatory framework, yet businesses now face overlapping pressures from labelling changes, proposed cost recovery and expanded regulatory requirements. This is how red tape grows: one requirement at a time until the cumulative burden threatens the businesses expected to carry it.

When regulation is not proportionate to risk, it creates barriers for businesses, innovation and, ultimately, consumers. What does this look like in practice?

For those of you here in Ottawa, you may remember this. In 2016, two young girls set up a lemonade stand. They had the table, the sign, the cups and that spark of childhood excitement that says, “This is the start of something big.” Then the government arrived. They were shut down and told they needed a permit to sell lemonade. Most Canadians saw that moment for what it was: red tape where common sense should have been.

Now, imagine that those same girls add one simple claim: “source of antioxidants for the maintenance of good health”. Those adjustments instantly turn their lemonade into a natural health product, and everything changes.

Despite the myth that natural health products are unregulated, those two little entrepreneurs would be pulled straight into one of the most complicated regulatory systems in the world for a low-risk product. They would be required to obtain a site licence to manufacture, package and label; host a government inspection; comply with good manufacturing practices, including stability and finished product testing and recall procedures; submit evidence demonstrating their claim is supported; follow bilingual labelling requirements; and file adverse reaction reports. Those requirements were put in place after careful consideration by this committee of what was required to safely regulate NHPs.

While all of this is happening, their neighbour south of the border can ship an identical product straight to Canadians with none of the above restrictions I mentioned and little to no government oversight.

When Health Canada told us they wanted to level the playing field with drugs, I had to ask, “Why aren't we levelling the playing field with competitors selling the same products directly to Canadians?” An analysis prepared for CHFA estimates that approximately $450 million in natural health products enters Canada annually through personal importation. The lemonade example makes this easy to picture, because it's often where small business ideas start but shows how easy it is to tip further into red tape.

For the businesses we represent, the costs are real and substantial. An independent analysis prepared for CHFA estimated that recent and proposed regulatory initiatives would add between $120 million and $170 million in annual compliance costs, plus $430 million to $1 billion in one-time implementation costs through 2028. For a small Canadian business, those costs mean difficult choices: whether to launch a product, hire an employee, raise prices or keep a product on the market at all.

Supporting this bill does not mean compromising the health and safety of Canadians. That's why we urge this committee to support Bill C-224 and protect something fundamental: the ability of Canadians to choose how they support their own health with Canadian products.

Thank you.

[The Chair, Liberal, Sukh Dhaliwal]

Thank you. That was perfect timing.

We will now go to Food, Health and Consumer Products of Canada.

Madam Roberta Kramchynsky, please go ahead for five minutes.

[Roberta Kramchynsky, Vice-President, Consumer Health Products and Regulatory Affairs, Food, Health and Consumer Products of Canada]

Thank you, Mr. Chair.

My name is Roberta Kramchynsky. I'm the vice-president of consumer health policy and regulatory affairs for Food, Health and Consumer Products of Canada. FHCP members are the manufacturers of the vast majority of natural health products and non-prescription drugs sold in Canada. FHCP greatly appreciates the committee's ongoing interest in the regulation of natural health products.

As was the case when we testified before this committee on Bill C-368 in 2024, FHCP holds that this bill will not address the regulatory challenges associated with natural health products. FHCP has no concerns with the current legislative framework of the Food and Drugs Act. We are concerned with regulatory requirements, how Health Canada applies them, and the resulting red tape and regulatory burden placed on manufacturers. However, changing the definition of “therapeutic product”, as proposed by Bill C-224, does not fix those problems. The definition of therapeutic product matters, because it gives the Minister of Health access to both modern safety powers and regulatory flexibility.

Vanessa's Law provides powers to order mandatory recall, fines and penalties, labelling changes, and requests for information, including confidential business information. The aim of Vanessa's Law was to modernize the tool box Health Canada uses to manage the regulatory environment, measures taken only when voluntary measures do not work. The new authorities made it possible to address safety issues without depriving Canadians of the products they rely on.

Separately, the Food and Drugs Act's precision-regulating authorities allow the minister to, among other powers, exempt therapeutic products from certain requirements when the statutory conditions are met. The recent experience with natural health product labelling shows why that flexibility matters. New labelling requirements passed in 2022 were scheduled to apply to newly licensed natural health products in June 2025. FHCP and other stakeholders raised concerns about unclear guidance, costly implementation and prescriptive requirements that were creating uncertainty regarding compliance and driving up costs for manufacturers. There were also real concerns for Canadian consumers—namely, fewer natural health products marketed in Canada and labels that were more complex and difficult to read and comprehend.

In response to those challenges, the Minister of Health issued an exemption order, exempting natural health products licensed on or after June 21, 2025, from those 2022 labelling requirements. The measure is in place while labelling reforms are designed and implemented. The relief offered by the exemption order was available because natural health products were included in the definition of a therapeutic product. If passed, Bill C-224 would remove most natural health products from that definition, and with it the access to this exemption authority. It would narrow the government's options for responding to regulatory problems like the one we have just experienced.

Mr. Chair, we recognize the committee's contribution to advancing natural health products reform. This committee's work has had a major impact on Health Canada's approach to NHPs and has helped accelerate regulatory reform. Today, Health Canada is pursuing a broad swath of changes to reduce red tape for natural health products, including new labelling regulations and guidance, and a registration process for low-risk NHPs.

FHCP and our members are working with the department to translate those commitments into practical improvements, but commitments are not enough. Manufacturers need clear requirements, predictable decisions and timely implementation in order to compete and grow. There is substantial work ahead. This window of opportunity won't last forever. All of these reform initiatives are moving forward at an exceptionally fast pace, which is crucial for industry in these trying economic times.

We agree that the current system needs to improve. The practical path forward is to complete the reforms addressing the burdens that manufacturers face while ensuring the safety and quality of the natural health products Canadians rely on.

For these reasons, FHCP does not support Bill C-224. We ask the committee to support timely and measurable regulatory reform that improves Canadians' access to natural health products.

Thank you for this opportunity. I look forward to the committee's questions.

[The Chair, Liberal, Sukh Dhaliwal]

Thank you.

The last witness we will go to is President Shawn Buckley for five minutes.

Please go ahead.

[Shawn Buckley, President, Natural Health Products Protection Association]

We're here to sort out whether natural remedies like vitamin C or calcium should be classed in the same categories of drugs as thalidomide and Vioxx. That's why we're here. The best way to answer that is to ask this question: Should natural health products be classed as drugs at all? They shouldn't. It's a matter of life and death.

The Natural Health Product Protection Association took video testimonies last year from Canadians across Canada whose very lives depend on access to natural health products. One of those was Karen Peters, who was debilitated with rheumatoid arthritis. Her medical doctor advised her that it was progressive and that she would end up in a wheelchair and then end up dead. To help manage this decline, she was on a couple of chemical drugs, including a chemotherapy drug. For a full year, she was being injected weekly with a chemotherapy drug. She explained that it made her so sick she wished she was dead. Then, after a year, she went to a naturopathic doctor, who took her off those drugs and cured her with natural health products, and she was no longer disabled. She's no longer facing a wheelchair, and she's no longer facing death.

This is one condition. There was condition after condition, and there are a ton of Canadians suffering because they can't be told. We're in the drug model, and under the drug model there's basically 100% censorship of truthful health information and of those who have the truthful health information. This is costing lives, and this is by design.

We also have to talk about the moral and ethical failure of being in the drug category. When we're talking about natural health products, we are largely talking about essential nutrients like vitamin D and magnesium—things that we need to stay alive, let alone thrive. Almost every other country in the world takes it as a basic human right that human beings have complete and free access to things they need to survive and to be healthy, but Canada does not. Because we're in the drug model, it is criminal. It's not just illegal. It's a criminal offence for anyone to sell us vitamin C or magnesium without Health Canada's permission in the form of a drug licence.

It's an incredible barrier. It has driven up the prices dramatically, so that lower-income Canadians can no longer afford to have the nutrients they need. We have an absolute legal failure here. We have a moral failure. I would say we have a spiritual failure. I call what we're doing evil, literally. We are putting a barrier between essential nutrients, which should be a basic human right, and the people accessing them.

Health Canada is going to come here and, like Chicken Little, say, “The sky is falling. The sky is falling. Risk, risk, risk.” You will never see Health Canada do a balanced risk analysis. What is the cost of restricting essential nutrients? What is the cost to all those Karen Peters out there who can't be told that they don't need to face suffering and death?

Again, Health Canada just says, “Risk, risk, risk. Oh my gosh, we have to protect Canadians.” The biggest thing that makes this an absolute fraud is that south of the border, we have 400 million Americans, and most of them use the exact same natural health products that we're talking about here. They're classified as foods. Congress looked into this and, in 1994, passed the Dietary Supplement Health and Education Act. They're classed as foods. They're deemed by law to be safe. They're legally protected and promoted.

In Canada, they're deemed by law to be unsafe, because we're in a drug model. We have to prove that vitamin C is safe before we can get a licence. They're the exact same products, and we have 300 million people using them every day, as we have had for the whole life of everyone here, without any problem. The FDA has not seen any problem. We used to be largely unregulated. Really, it wasn't until 2017. I know the regulations came into force in 2004, but we couldn't comply. Health Canada just kept passing regulations. We don't need to be in the therapeutic product category for the Minister of Health to exempt us for temporary periods. That's just not a true thing.

How can it be that we have to regulate these as drugs? How can we possibly argue that these are dangerous and need to be classed as drugs, when they're not classed as drugs south of the border? It's already been brought up. The other part of the fraud is that you're free to order those products. I'm free to order those products. Anyone watching this is free to order those products, because nobody sees that as a problem.

We are ordering those products because they're cheaper. They're four to five times cheaper where there used to be largely parity, and low-income Canadians can no longer get nutrients.

[The Chair, Liberal, Sukh Dhaliwal]

Thank you very much.

Before we start with Madam Dancho, I would love to welcome MP Blaine Calkins to the meeting.

Welcome.

[Blaine Calkins, Conservative, Ponoka—Didsbury, AB]

Thank you, Chair.

[The Chair, Liberal, Sukh Dhaliwal]

Now, for the six-minute round, we'll go to our vice-chair, Madam Dancho.

Please go ahead.

[Raquel Dancho, Conservative, Kildonan—St. Paul, MB]

Thank you, Mr. Chair.

Thank you to our expert witnesses for being here today. We appreciate your perspectives on this very important debate that we're having at the health committee on regulations for natural health products. As you know, what we decide at this committee with Bill C-224 will impact the choices and daily lives of millions of Canadians who use natural health products every day.

Of course, products such as vitamin D, vitamin C, multivitamins, magnesium, calcium, iron, prenatal vitamins, melatonin, probiotics, omega-3s, fish oil, fibre supplements, herbal remedies and traditional and cultural medicines, and even things like fluoride toothpaste, anti-dandruff shampoo, antiperspirants and other medicated personal care products are very common. What their future is in Canada is being debated during this committee meeting today and will be in the weeks to come. Certainly, many of us who rely on Canadian brands specifically—and, of course, on products regulated and sold in Canada—will be impacted.

The Conservative team is very concerned that without the passage of Bill C-224, the Canadian health industry will suffer, to the benefit of the American economy. Our goals are to ensure that our Canadian industry continues to thrive and that Canadians have agency over their health and the freedom to choose how they will maintain it.

My first questions are for Ms. Parmar.

There seems to be a bit of sentiment out there from some corners of this debate that natural health products aren't regulated or are not well regulated. Of course, we know that couldn't be further from the truth.

Ms. Parmar, could you share with the committee how natural health products are regulated in Canada? In brief, what process is there for getting your product onto a shelf, for example?

[Sonia Parmar]

Natural health products are heavily regulated, as I mentioned in my speech, especially when compared with those in other jurisdictions. We have a prelicensing system that does not exist in other countries, necessarily, especially in the United States, as well as Australia. We've done a very close comparison.

As well, I will ask our lawyer, Ms. Gomez, to speak to the powers that already exist currently and how they compare in this situation.

[Laura Gomez, Lawyer and Legal Counsel, Canadian Health Food Association]

In Canada, Health Canada has a lot of authority to mandate requirements as they relate to NHPs. We have a premarket system for both the licensing of the products and the facilities that import, manufacture, package and label natural health products. These must all be licensed by Health Canada, and we have to provide documentation to Health Canada in order to obtain those licences. Health Canada also has the authority to inspect those facilities.

If there are issues with the products identified, which can be when they're inspecting, or through safety information that comes to their attention from other countries, they can then take certain actions. They can ask companies to provide information or update their labelling. They can also suspend or cancel a licence if companies do not comply. That applies to both the product licences and the site licences for the facilities themselves.

[Raquel Dancho, Conservative, Kildonan—St. Paul, MB]

Thank you very much.

For either of you, what makes this regulation different from pharmaceuticals? Why should natural health products be regulated differently?

[Laura Gomez]

For natural health products, when the 53 recommendations came out, they were looking at how natural health products are used. One of the key distinctions legally is that natural health products can be used for the maintenance of good health. That's not something that forms part of the definition of a drug product.

When they studied this issue, they went through all the different ways that natural health products should be regulated, and they were proportionate in determining what to establish for natural health products. They considered very specific requirements: how people use these products, what type of testing should be applied, how frequently facilities should be managed, and who should be working in the directorate that approves these products. They went through and designed 53 recommendations. It's quite robust. The natural health product regulations were designed around that, which is why it was viewed legally for many years as a model for other countries to follow.

When you combine the therapeutic product regulations, what you're essentially doing is applying a regulatory regime that was designed to address very specific gaps that Health Canada had in addressing pharmaceutical drug products. That also includes the fact that the regime was 50 years old. For natural health products, it's a modern regulatory regime, because it was developed in 2004.

[Raquel Dancho, Conservative, Kildonan—St. Paul, MB]

Thank you very much.

To be clear, those 53 recommendations were decided at this committee in 1998. It was one of the largest studies I've ever heard of. It went on for eight months. It had 300 live presentations; 150 individuals, associations and coalitions; and 1,000 written submissions that the Chrétien government at the time fully adopted. That really brought in our current regulatory regime.

Really, what you're talking about is that the committee and the government thereafter for decades looked at risk-based...as well. Those are the words I kept hearing. What is the risk of a calcium supplement relative to a benzodiazepine, for example? Of course they should be regulated differently. What is the risk of a ginger tea versus something else quite serious? Of course those things are not the same and shouldn't be regulated the same way.

What are some of the costs to natural health products and Canadian companies with this increasing push to pharmaceuticalize, if I could use a made-up word, the natural health products regulations? What are some of the costs there, in brief, please?

[Sonia Parmar]

We're anticipating $105 million to $165 million in excess red tape.

[Raquel Dancho, Conservative, Kildonan—St. Paul, MB]

Wow. That's crushing for Canadian companies trying to get their products out, hiring Canadians and manufacturing their products, and it's crushing to the stores that sell the products. Canadians will have fewer options from Canada. That's really devastating.

Thank you very much.

[The Chair, Liberal, Sukh Dhaliwal]

Thank you. That was perfect timing.

We'll go to Parliamentary Secretary Chi for six minutes.

Please go ahead.

[Maggie Chi, Liberal, Don Valley North, ON]

Thank you, Mr. Chair.

Thank you to all the witnesses for appearing today.

I think it's important to recognize that natural health products are an important part of millions of Canadians' everyday health routines. We're talking about products ranging from vitamins and probiotics to traditional herbal medicines. Canadians want access to these products. At the same time, they want to be able to count on a robust system that gives them confidence that the products they buy are safe and regulated, and that government can act when problems arise.

I have a couple of questions for Ms. Kramchynsky.

As you know, Canada already has a regulatory framework for natural health products that is separate from prescription drugs. I think you touched on it in your opening testimony. FHCP has expressed support for the self-care framework and a more modern, risk-based approach to both natural health products and over-the-counter drugs.

What does a more modern regulatory system look like, especially in terms of balancing getting products to market efficiently—so that consumers get faster access—and maintaining a strong postmarket oversight?

[Roberta Kramchynsky]

I think it's a really interesting time right now in the space of consumer health care products.

As you mentioned, FHCP represents manufacturers of natural health products as well as manufacturers of over-the-counter medicines. I think we've been really encouraged by recent efforts from Health Canada that have identified how to address reducing red tape for natural health products as well as, separately, over-the-counter medicines or non-prescription medicines.

What we're really seeing here is that there is a lot of work happening at that regulatory level to modernize and reduce red tape. As I look at what Bill C-224 proposes and those changes to the Food and Drugs Act, I see that they are actually going to impact those modernized components of the Food and Drugs Act itself. This removes some of the flexibility we see that has been beneficial to address challenges such as labelling in 2025, as I mentioned in my opening statement.

When I'm looking at what work is happening right now and the challenges that we've seen, I see that we actually agree with a number of our counterparts on this panel. There are a lot of challenges in how reforms have been approached in the past. There are a lot of challenges in the cost of implementation and in finding paths forward. Particularly since the red tape reduction reports in September 2025, I think we've seen an active regulatory reform agenda rolling out at Health Canada, engaging stakeholders in multiple consultations and conversations over the course of the past year, and it's moving forward quickly.

I think that regulatory reform element is actually where we will find the solutions to those challenges we see in the regulatory system. Having access to more agile and modern legislative tools is incredibly important and enables modernization. That's really important for manufacturers in ensuring that Canadians can access the products they rely on.

[Maggie Chi, Liberal, Don Valley North, ON]

Thank you so much.

I have a follow-up to that. Does this proposed bill address any of those regulatory concerns that your members have? I think a point was raised about impact on consumer choices. Is there any impact on that as well?

[Roberta Kramchynsky]

As we're considering what Bill C-224 does in practice.... It gives access to the powers of Vanessa's Law, which are designed for consumer protection. They're also designed to be measures that are used as a last resort after voluntary measures have failed. Those voluntary measures that we refer to there are the ones you find in the regulatory framework. That is the existing natural health products regulations, their system of that premarket assessment, the postmarket monitoring and analysis that happen, and the inspections and oversight of those products when they're on the market.

Overall, if we look at what Bill C-224 does, we see that in essence it takes away that agile framework and those agile tools. As we're working through regulatory reform with the department, it really will hamper the ability for natural health products to be regulated in an agile system going forward.

[Maggie Chi, Liberal, Don Valley North, ON]

Thank you so much.

As you mentioned, our regulatory system in Canada is about protecting the health and safety of Canadians. In your previous testimony, when a previous version of the bill was presented, I think it was mentioned that the stamp of approval from Health Canada is part of what makes our products competitive globally.

I want to ask, what are some of the risks if we do pass this bill?

[Roberta Kramchynsky]

Some of the risks we could see.... In particular, one of the real success stories of the natural health product regulations has been their impact on Canada's ability to export natural health products to other jurisdictions that look to Health Canada's review and the issuance of a natural product number as a strong statement of the quality of those products. Essentially, we saw the sales and the overall size of the natural health product industry double in the first 10 years, and it has continued to grow since then.

A number of our members export their Canadian-made products to countries around the world. I've also worked with counterparts in global trade associations in other parts of the world who recognize the strength of Health Canada's system and recognize it as an endorsement of quality and safety. That's really reflected in those products that are exported around the world.

[Maggie Chi, Liberal, Don Valley North, ON]

Thank you so much. I think that's my time, Chair.