As a long-time advocate for a consistent, risk-based approach to health product regulation, Consumer Health Products Canada applauds the basic thrust of the CMAJ editorial “No regulatory double standard for natural health products.”1 Consumer health products used in the practice of self-care can make a positive difference in the lives of Canadians and contribute greatly to the cost-effectiveness of the Canadian health care system. However, natural health products can do this consistently only if the regulatory system that authorizes their approval for sale is evidence-based and enforced in the marketplace.
More than seven years after they were introduced, the natural health products regulations are still not being fully enforced. The consumer confusion mentioned in the CMAJ editorial1 is real and will not go away until all products on pharmacy and health food store shelves meet appropriate and consistent standards of safety and efficacy and are labelled in clear consumer language consistent with the terms of product approval — as would be required by the natural health products regulations were they fully enforced. The members of Consumer Health Products Canada, who derive about half of their sales from products regulated under the natural health products regulations, are eager for the regulations to be fully enforced, but others may be less eager because of the potential economic effect.
It is time to put the health of Canadians and, in view of the key role that evidence-based self-care can play in providing cost-effective care, the health of the Canadian health care system ahead of the economic interests of companies that don’t want to comply with relatively modest regulatory requirements. Consumer Health Products Canada agrees with your editorialists that broader changes to health product regulations may be desirable and bring more consistency in the longer term. But in the meantime, simply enforcing the existing regulations would be a logical step and the minimum government should do to support Canadians who want to practise responsible self-care.