Now is a crucial time for the industry to act and speak as one.
In May, Health Canada released their Cost Recovery for Natural Health Products (NHPs) proposal. Canada is already one of the most complex countries to sell NHPs and this proposal will add high costs to the existing challenges for direct selling companies that market products in this category. Products impacted include items such as, vitamins, minerals, herbal remedies and homeopathic medicines.
Features of this proposal include the introduction of a new fee-for-service model for companies wishing to seek approval to sell NHP products, both at the time of initial product submission (NHP Product Licence Applications [PLA]) and on an ongoing yearly basis (Annual Right to Sell [RTS] NHPs). There would also be fees introduced for site licences (NHP Site Licence Applications [SLA]).
DSA Canada believes that this proposal would:
- Greatly increase costs for companies doing business in Canada and discourage new companies from entering the market.
- Punish innovative businesses and harm the research and development of new products.
- Reduce consumer choice and increase consumer costs.
- Decrease earning and entrepreneurial opportunities for independent sales consultants involved in direct selling.
- Drive companies to sell products via unregulated online marketplaces, utilizing Health Canada’s personal use (NFR) import exemption, potentially harming consumer safety.
- Not, in any way, lead to improvements in Health Canada’s service standards.
DSA Canada is advocating on behalf of all direct sellers for this proposal to be significantly changed, to recognize the economic impacts it will have on our industry. We are lobbying through official channels, utilizing traditional and social media, and working with likeminded stakeholders, to achieve a successful outcome.
We are calling on all direct sellers to get behind us in these efforts. Current members have the opportunity to help build our response and advocacy actions; and potential members, particularly those who market NHPs, should consider this an optimal time to join the fight with DSA Canada.
Please contact Peter Maddox, DSA Canada President, at firstname.lastname@example.org to discuss how you can get involved.
Review of the proposal and fee table
DSA Canada Supplier Member, Gowling WLG, breaks down the proposal and the associated fee table in their recent article, Health Canada’s proposal on cost recovery for natural health products raises questions. According to Gowling WLG, the fees proposed are higher than anyone could have expected, e.g., up to $60k for the approval of a complex NHP. Under the current regime, there are no fees for any of the services outlined.
Health Canada is providing a 75-day consultation period (closing July 26), seeking feedback on the proposal from industry, consumers, and all Canadians.
DSA Canada will be making a submission to government as a part of this consultation. A Member Working Group is being convened to provide input on this submission and on other advocacy on the proposal.