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Submission made on the negative impact proposed fees on NHPs will have on industry and Canadians

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Date: 16 Aug, 2023

We recognize that a fair and well managed natural health product (NHP) regulatory framework is vital for consumers who purchase and utilize these products, and for companies who market them, including our members. For this reason, we have made a formal submission to Health Canada, outlining our concerns with their proposal to introduce a new fee-for-service model for companies who license and sell NHPs in Canada. Thank you to all of our members who participated in developing this submission.

Having considered Health Canada’s proposal, we are concerned that if implemented as written, it will have negative impacts on both industry and consumers. Our submission outlines these concerns, which include the likely impact on innovation, entrepreneurship, economic prosperity, and business investment.

In our submission, we recommend that the consultation on this proposal is extended, and implementation delayed, to allow stakeholders to collaborate on developing a world class regulatory model that works for all. This must include detailed economic modelling being completed, and a road map being developed to specify how existing problems with NHP and self-care product regulation in Canada will be fixed.

It is important that all aspects of the proposal be further deliberated, including fee structure and rates, service standards, mitigations, and timelines. We welcome opportunities to participate in these deliberations, as part of the broader Self-Care Framework conversation.

Read our submission