Health committee  Thank you for the question. There are hundreds. That is very small. It's almost a rounding error, regarding the industry. That being said, it's worth emphasizing that the kind of inspection program that makes sense is a risk-based one. You have to target places where you think there is the most likelihood of a problem that can be rectified.

Health committee  No. I think economically they're completely different models. In terms of the impact of cost recovery on the public purse, there's a fundamental difference between the two. As you pointed out, they're not covered by health plans. The reason they're not covered by health plans is that they're not considered eligible expenses under the medical expense tax credit.

Health committee  The fee ratio—in other words, the proportion of the total costs born by government that is billed to industry—is exactly the same.

Health committee  Exactly.

Health committee  Either way, the consumer ultimately pays, so I don't think there's a question mark around that. You're right. Whether it's charged to industry or whether it comes in the form of a tax, the issue is getting the regulatory reforms in place so we have a comprehensive approach that deals with a rebalancing of this premarket versus postmarket and inspections issue.

Health committee  I would agree. I think the industry has, for a long time, had a concern with Health Canada's approach, which is very heavy on premarket activities and the licensing system, which is, quite frankly, in most categories, heavily backlogged right now, but they have not been enforcing in the field.

Health committee  Sure. When cost recovery was first introduced in Health Canada's health products area in 1994, I was an active participant at that point. We saw a second revision of the cost recovery regime in the decade just past. In each of those cases, the Government of Canada set down very clear rules that distinguish between cost recovery fees, regulatory charges, service fees, etc., and created very clear rules for how they have to be constructed.

Health committee  Thank you, Mr. Chairman and members of the committee, for this opportunity to provide our industry's perspective on the Department of Health's regulatory changes for natural health products. FHCP members account for more than half of the NHPs sold in Canada. This includes familiar products like vitamins, minerals and herbal remedies, but also some things you may not necessarily think of as natural health products, such as nicotine patches for smoking cessation.