Health Committee on Oct. 5th, 2026

[Roberta Kramchynsky]

In short, yes, it did. Through FHCP, we also represent makers of non-prescription drugs. As a result of Vanessa's Law, they underwent a plain language labelling regulatory change in the mid-2000s, when we did see, in particular, that it raised the cost of labelling. Manufacturers did incur significant cost increases for those labels.

It also saw the use of things like flexibilities for how we can apply the correct information onto a label and the use of something called “innovative labels”. If you've ever seen a bottle on the shelf in your pharmacy with one of those peel-backs, that's an innovative label. It's needed to ensure that there's room for all of the required information to be on that product. Those are actually very costly and add a lot of complexity to the packaging and labelling process.

We had that experience with OTC PLL, and now we are seeing it through the NHP labelling regulations, which is part of the reason that I've been looking at what's being proposed under red tape reduction. We're having conversations around how we can ensure both that labelling is flexible enough for manufacturers, so that consumers have access to the information that they need, but also, in looking ahead, that there may be some components of digital labelling we can use that reduce that time from label change to information actually being in the hands of consumers.

It's still very early days, but I think those are the types of reforms we're looking at that will help to reduce costs for manufacturers while ensuring that consumers are protected because they still have access to the product information they need to use that product safely.

[The Chair, Liberal, Sukh Dhaliwal]

You have 50 seconds.

[Sonia Sidhu, Liberal, Brampton South, ON]

That's it. Thank you, Mr. Chair.

[The Chair, Liberal, Sukh Dhaliwal]

Thank you.

Now we will go to Madame Gaudreau for two and a half minutes. Please go ahead.

[Marie-Hélène Gaudreau, Bloc, Laurentides—Labelle, QC]

Thank you, Mr. Chair.

I have just one question, but it's for the three witnesses.

Unfortunately, the bill doesn't include the amendments adopted during the last Parliament when Bill C‑368 was being studied. You probably remember that one of the amendments moved by the Bloc Québécois was to retain the mandatory recall power for natural health products. We would like to continue down this road. I would like to hear your thoughts on this matter.

Mr. Buckley, what are your thoughts?

[Shawn Buckley]

That's a great question.

You've already heard me talking about recalls. There's a piece of draft legislation called “The Charter of Health Freedom”. You can go to charterofhealthfreedom.org. There's a recall provision in there that would allow a court to manage, because we all agree.... Ironically, for the most dangerous chemical drugs, again, it's interfering with the doctor-patient relationship, and the regulatory body cannot know which patients depend on a product and the like. Even if there's spiking or adulteration or something in a specific lot, we still need to have the court supervise.

Now, for the court, you don't even need to have a new law. We have it in the Food and Drugs Act that the court can supervise. Before the Food and Drugs Act put that in, courts would order recalls and supervise. It's not something that we even need in the act, but if we do that, we should recognize that a recall interferes with patient-client relationships. The goal is the best health outcomes, but as it is, Health Canada can order a recall without any consideration of that.

I think that for the best outcomes I would encourage this committee to look at a recall provision that would also take into account that you're interfering with doctor-patient relationships. The last time I checked, the medical doctors out there were trying to manage their patients as effectively as possible, and they should have some say if that's being interfered with.

[Marie-Hélène Gaudreau, Bloc, Laurentides—Labelle, QC]

Ms. Gomez, I have 30 seconds left. I would appreciate a quick response.

[Laura Gomez]

In order to have a recall power, natural health products do not need to be under the definition of therapeutic products. That could be a framework that is in place for natural health products. It's in place for other types of consumer products.

I think the main issue with this bill is that in order to achieve its goals, Health Canada just put natural health products entirely in the category of therapeutic drugs, which is not required legally.

[The Chair, Liberal, Sukh Dhaliwal]

Thank you.

Now we will go to Mr. Calkins for five minutes.

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

Thank you, Chair.

I think what's been lost a bit in the conversation here is that what we're talking about is pre Bill C-47 and post Bill C-47, when the change to therapeutic drugs in the definition of natural health products actually happened.

It's been intimated by people at the committee today, I think, that there wasn't a regulatory process in place for natural health products prior to Bill C-47. As a matter of fact, Ms. Kramchynsky suggested that because of Bill C-47, the robust reputation of the Canadian natural health products industry is now solid.

Was it not solid prior to Bill C-47, Ms. Parmar?

[Sonia Parmar]

Yes, I would definitely say that it was solid. We have done safety reports. We have a number of safety reports that suggest the adverse events are very low and there really was no concern to drive this level of regulatory reform at this point.

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

I was around when Vanessa's Law was passed. I know Mr. Young personally. He was a Conservative member of Parliament. The name of the legislation was the Protecting Canadians from Unsafe Drugs Act. At no point in time, in any conversations that I've ever had with Mr. Young, did he suggest that his intent for Vanessa's Law was to implicate or interfere with the natural health product industry.

Can you tell us how many Canadians actually use natural health products? What percentage of those Canadians and those businesses are women? Who are the consumers, and what are they buying these natural health products for? Is it mostly women shoppers buying for their families?

What will be the health impacts if we lose that access to our American counterparts, who do not have premarket approval for any of their products, and how is that in any way, shape or form making the Canadian consumer safer?

[Sonia Parmar]

Over 82% of Canadians use natural health products. The vast majority of those are women. They are known to be the shoppers of the family, and they themselves, largely, are taking the products as well.

There are major impacts, as we've been told by our retailers. We represent not only manufacturers. We also represent distributors, retailers and the entire supply chain. Canadians are walking into retailers and showing them products they find online that are very cheap and that in some cases are potentially risky, and they are buying them online because they can't find them in shops, or they find them much cheaper.

This is why there may be some unintended consequences. Whether Health Canada actually intends to create this situation or not is not what we're debating. It's a fact that this is what's happening. This is what's happening on the ground, and our retailers face this every single day. In fact, we have seven locations.... One natural health food store has closed in Ottawa, due in part to the competition that it has, not only with other companies within Canada, but with U.S. companies as well.

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

Does it make sense to you, Ms. Parmar, that the natural health product industry should involve itself with the therapeutic industry in order to get exemptions from the very rules they're implicated in with the drug industry? That seems to be an argument that's being made here today: Let's roll ourselves up in red tape, just so that we can go through the red tape reduction process to get ourselves out of the red tape.

Wouldn't it be smarter just to not involve ourselves in the red tape in the first place?

[Sonia Parmar]

Yes. That's correct.

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

Good. Thanks.

Mr. Buckley, can you give us any type of ballpark number of Canadians who say that their lives actually depend on being able to access safe natural health products from Canada?

[Shawn Buckley]

I don't think we can say. The reason is that it's somewhat hidden. The reason the NHPPA started taking testimonies last year, with videos for people to watch, is that we have 100% censorship. When it's a drug, it gets approved for a label claim. Vitamin C might have that it maintains teeth and bones. You can't say anything else. You can have peer-reviewed published research. You can have government-funded research. You can't say anything else.

Perhaps I can put into context the safety issue, if you don't mind. In risk analysis, if a class of products causes only one death per million of a population per year, then it's considered de minimis, or ultra safe. You don't even dare regulate at that level, because the safety signal is so low that you can't tell whether or not you're making a difference. Well, we included in the NHPPA brief a risk analysis by Professor Ron Law, an expert in risk analysis, using Canadian government statistics. This was just before our regulations came into force. Canadians were 17 times more likely to be struck by lightning than to be harmed by a natural health product.

Now, we would not put lightning poles all over Canada to try to reduce lightning strikes, which are one in four million, because we couldn't measure if we were making a difference. The safety signal is too low. We are so much lower than that. Never before has such a.... Like, why are we regulating these at all? It feels like we should be asking how many angels can dance on the end of a pin.

[The Chair, Liberal, Sukh Dhaliwal]

Thank you.

We'll go to Mr. Sawatzky next, for five minutes.

Please go ahead.

[Jake Sawatzky, Liberal, New Westminster—Burnaby—Maillardville, BC]

Thank you, Chair.

I'd like to start by asking Mr. Buckley two yes-or-no questions.

Number one, were you involved with the drafting of this bill in any capacity?

[Shawn Buckley]

Yes. Prior to Bill C-368, I suggested some wording on the bill.

[Jake Sawatzky, Liberal, New Westminster—Burnaby—Maillardville, BC]

Thank you.

Have you had any meetings or conversations with MP Blaine Calkins about the drafting or contents of this bill?

[Shawn Buckley]

Yes.

[Jake Sawatzky, Liberal, New Westminster—Burnaby—Maillardville, BC]

Okay. Thank you.

I'd also like to put it on the record that Health Canada should not need to consult the courts to order a recall if they're aware of a contaminated or toxic product. Health Canada doesn't need to apply to court for a recall to protect Canadians when milk or other foods are contaminated, so I don't believe it should have to do that for NHPs either.

My next questions are for Ms. Kramchynsky—

[Shawn Buckley]

Can I just clarify? I'm sorry. It's just that you asked if I had.... I don't think I had any conversations with Blaine, but there might have been emails with his office suggesting this or that.

[Jake Sawatzky, Liberal, New Westminster—Burnaby—Maillardville, BC]

Okay. Thank you, Mr. Buckley.

Ms. Kramchynsky, since 2023, Vanessa's Law authorities have applied to NHPs. This gives the minister the ability to order a recall where an NHP represents a serious or imminent risk to injury or health. If Bill C-224 removes NHPs from the definition of therapeutic product, this specific authority would no longer apply to NHPs.

If Health Canada identifies an NHP that is contaminated with lead, E. coli or another dangerous substance, and the company refuses to voluntarily recall the product, what specific statutory authority would Health Canada have under Bill C-224 to compel an immediate recall?