Canadian Health Food Association. Pre-budget consultations in advance of the 2018 budget

Similar documents
Canada s Intellectual Property (IP) Strategy submission from Polytechnics Canada

APEC Internet and Digital Economy Roadmap

Brief to the. Senate Standing Committee on Social Affairs, Science and Technology. Dr. Eliot A. Phillipson President and CEO

the Companies and Intellectual Property Commission of South Africa (CIPC)

Draft executive summaries to target groups on industrial energy efficiency and material substitution in carbonintensive

Fostering Seed Innovation

Upstream Oil and Gas. Spill Prevention, Preparedness, Response, and Recovery. March 2013

What We Heard Report Inspection Modernization: The Case for Change Consultation from June 1 to July 31, 2012

Government Policy Statement on Gas Governance

EXPLORATION DEVELOPMENT OPERATION CLOSURE

CanNor Building a Strong North Together Strategic Framework CanNor.gc.ca

The ICT industry as driver for competition, investment, growth and jobs if we make the right choices

EMBARGOED TILL DELIVERY

OECD Innovation Strategy: Key Findings

Submission to the Productivity Commission inquiry into Intellectual Property Arrangements

Written Submission for the Pre-Budget Consultations in Advance of the 2019 Budget By: The Danish Life Sciences Forum

B) Issues to be Prioritised within the Proposed Global Strategy and Plan of Action:

A STRATEGY TO IMPROVE CANADA S MINERAL EXPLORATION INVESTMENT CLIMATE

Pan-Canadian Trust Framework Overview

ITI Comment Submission to USTR Negotiating Objectives for a U.S.-Japan Trade Agreement

Canada s Research-Based Pharmaceutical Companies (Rx&D) 2015 Pre-Budget Submission House of Commons Standing Committee on Finance.

DIGITAL FINLAND FRAMEWORK FRAMEWORK FOR TURNING DIGITAL TRANSFORMATION TO SOLUTIONS TO GRAND CHALLENGES

Your Excellency, President of the Socialist Republic of Vietnam Tran Dai Quang. Minister and Chairman of the President s Office Dao Viet Trung

market development out of our comfort zone RICHARD MATHESON

Advancing Health and Prosperity. A Brief to the Advisory Panel on Healthcare Innovation

The petroleum industry, internationalisation, 11 and technology development. Industry development and internationalisation

Bayer Inc. Science for a Better Life. Talking with Phil Blake, President, Bayer Inc., HealthCare Representative and Head, Pharmaceuticals Division

MILAN DECLARATION Joining Forces for Investment in the Future of Europe

A stronger system to protect the health and safety of Canadians. Exploring the Future of the Food Regulatory Framework Under the Food and Drugs Act

Translation University of Tokyo Intellectual Property Policy

The Value of Membership.

INTELLECTUAL PROPERTY (IP) SME SCOREBOARD 2016

INTELLECTUAL PROPERTY (IP) SME SCOREBOARD 2016

The 26 th APEC Economic Leaders Meeting

Speech by the OECD Deputy Secretary General Mr. Aart de Geus

CIPO Update. Johanne Bélisle. Commissioner of Patents, Registrar of Trade-marks and Chief Executive Officer

handbook 30 Questions to Ask Before Becoming an Independent Business Owner

Expanding and positioning Uganda s technical capabilities for the oil and gas industry

Globalisation increasingly affects how companies in OECD countries

Sparking a New Economy. Canada s Advanced Manufacturing Supercluster

Executive Summary Industry s Responsibility in Promoting Responsible Development and Use:

MINISTRY OF ENERGY AND PETROLEUM (MPE) ON NORWAY S PETROLEUM ACTIVITIES: WHITE PAPER (2011) AND THE STATE

Metrology at NRC Canada: An NMI in an RTO Context

Food and Drugs Act Liaison Office. Report on Activities April 2015 March 2016

Insights into Mining. Incremental innovation. Is it the right approach for mining?

As Minister of Heritage James Moore said in his speech at the Canadian Media Production Association Prime Time Conference on February 17, 2011:

May 25, Comments of ACT The App Association on the Department of Telecommunication s Draft 2018 National Digital Communications Policy

Spectrum and licensing in the mobile telecommunications market

Patenting Strategies. The First Steps. Patenting Strategies / Bernhard Nussbaumer, 12/17/2009 1

TEC ENTERPRISES CORP.

Canada : Innovation and Inclusion in the Network Age

A Focus on Health Data Infrastructure, Capacity and Application of Outcomes Data

CRS Report for Congress

PRE-BUDGET CONSULTATIONS 2010 August 13, 2010

TRANSFORMATION INTO A KNOWLEDGE-BASED ECONOMY: THE MALAYSIAN EXPERIENCE

State Content Standards for New Mexico

DESIGN THINKING AND THE ENTERPRISE

Franco German press release. following the interview between Ministers Le Maire and Altmaier, 18 December.

Reach for the skies. The Aerospace Growth Partnership. Industry and government working together to secure the future for UK aerospace

EASY ACCESS IP AN INTRODUCTION FOR UTS RESEARCHERS FEBRUARY 2014 RESEARCH & INNOVATION OFFICE

JUST SCRATCHING THE SERVICE

CABINET SECRETARY S SPEECH DURING THE OFFICIAL LAUNCH OF THE ONLINE TRANSACTIONAL MINING CADSTRE SYSTEM Salutations

FY2013 Indicative Work Programme and Budget Co-regulatory Forum. 18 November 2011

Reputation enhanced by innovation - Call for proposals in module 3

A Science & Innovation Audit for the West Midlands

Climate Change Innovation and Technology Framework 2017

RECOMMENDATIONS. COMMISSION RECOMMENDATION (EU) 2018/790 of 25 April 2018 on access to and preservation of scientific information

2010/3 Science and technology for development. The Economic and Social Council,

Maximizing Innovation Funding for Technology Development. MNP SR&ED Team. Presented by: Date:

on Mineral Development MINING THE FUTURE A Plan for Growth in the Newfoundland and Labrador Mining Industry

TRIUMF ACCELERATING CANADIAN BUSINESS THROUGH SCIENCE AND INNOVATION Pre-Budget Consultation

Executive Summary. Introduction:

UNITED STATES INTERNATIONAL TRADE COMMISSION WASHINGTON, DC 20436

A PLATFORM FOR INNOVATION

Extract of Advance copy of the Report of the International Conference on Chemicals Management on the work of its second session

EU Support for SME Innovation: The SME Instrument

DIRECTION OF SCIENCE, TECHNOLOGY AND INNOVATION POLICY IN THAILAND

HealthTech: What does it mean for compliance?

Mining Innovation: The Importance of Science Entreprise

EDQM COUNCIL OF EUROPE CONFERENCE CERTIFICATION PROCEDURE : 20 YEARS OF EXPERIENCE March EDQM, Strasbourg, France ABSTRACTS

Building an enterprise-centred innovation system

Engaging Industry Partners

Mineral Beneficiation Downstream Opportunities and Challenges!

Intellectual Property

ITAC RESPONSE: Modernizing Consent and Privacy in PIPEDA

Working together to deliver on Europe 2020

SME Toolkit Caribbean A Republic Bank Perspective

Food Agility CRC SHARING DATA TO BUILD BRAND, MARKETS, JOBS AND EXPORTS. Bid Summary

Digital Identity Innovation Canada s Opportunity to Lead the World. Digital ID and Authentication Council of Canada Pre-Budget Submission

THE AMERICAN INTELLECTUAL PROPERTY LAW ASSOCIATION RECOMMENDATIONS REGARDING QUALIFICATIONS FOR

DTI 1998 Competitiveness White Paper: Some background and introduction

Draft resolution on Science, technology and innovation for. Technology for Development as the United Nations torch-bearer

European Charter for Access to Research Infrastructures - DRAFT

In-Country Shared Value Creation The Case of Ghana

2016 Executive Summary Canada

Technology transfer industry shows gains

Economic and Social Council

Natural Health Products Directorate Update

SCIENCE AND TECHNOLOGY POLICY ICELAND

Importance of SMEs in Greening the Economy in Georgia

Transcription:

Canadian Health Food Association Submission to the House of Commons Standing Committee on Finance Pre-budget consultations in advance of the 2018 budget Executive Summary Every year, $7 billion is contributed to the Canadian economy by the country s natural health and organic products industries. These sectors continue to grow by fostering innovation and competition, and employ thousands of Canadians across the country. The Canadian Health Food Association (CHFA) represents more than 1,000 member companies within these fields. Seventynine per cent of Canadians rely on natural health product (NHPs) for maintaining their health lifestyle, and our members are proud to be a trusted source. The term NHP includes vitamins and minerals, herbal products, traditional remedies (such as Traditional Chinese Medicines), sports nutrition products, probiotics, and enzymes. The businesses we represent and the large customer base they serve remain concerned with the effort to modernize regulations, which may lead to Health Canada limiting their ability to compete in an increasingly challenging global market. Furthermore, these measures will limit the overall productivity of the NHP sector by upsetting the balance that has resulted over the years from government-industry collaboration on the development of guidance and standards. CHFA worked closely with government officials long before the implementation of the Natural Health Products Regulations in 2004. The result of this, which exists today, is an environment in which Canadians can trust that the NHPs they consume are safe, effective and high-quality. Our association recognizes the need for the regulation of all health products, and we have worked with our members to ensure that they abide by these rules. Under this regime, Canadians have shown that access to these products, along with an assurance of quality, are important to them, as demonstrated through continued market growth. Processes are currently underway to review the self-care products framework. It is vital that these processes and the resulting policy respect the unique qualities of NHPs, the importance of choice and access to consumers, and cultural approaches to wellness. We recommend that government take the following steps to ensure businesses in this growing sector remain competitive and productive. Strong Regulation Has Supported a Strong NHP Industry The government is committed to ensuring businesses can succeed and grow in Canada. In the case of our industry, however, the most important issue facing the $3 billion NHP industry is uncertainty surrounding the proposed self-care products framework, and how it can impede development and innovation.

Since the introduction of the Natural Health Products Regulations, over 100,000 products have been licensed, after being subject to pre-market review and approval by Health Canada for safety and efficacy. Because of this system, Canada is seen as a world leader in NHP regulation. This has not only increased consumer confidence in these products, but also helped our industry to grow and create jobs. Health Canada s review to change these regulations has been ongoing since 2014. At the current stage of the consultation process, the importers, distributors, manufacturers and retailers of NHPs have been left wondering about the future of the products they confidently offer to their customers, after having spent years ensuring compliance with the current Natural Health Products Regulations. Over the course of the consultation sessions, we have seen a number of positive changes to the initial proposal, but more work needs to be done. The self-care products framework must ensure that Canadians from all backgrounds continue to have access to the safe and effective products they use, with consideration for products from around the world that are culturally important and that have been used for centuries. To ensure competitiveness and productivity for businesses in our sector, government should ensure that impacts on the NHP supply chain are limited, as the existing regulations work well to ensure safety, efficacy and create trust. Under the proposed self-care products framework, businesses may need to once again reformulate their products, relabel their packaging, or invest substantially in additional research on products that are already deemed effective and safe, as indicated by their current sale in Canadian stores and safe use by consumers. A further concern relates to confusion about labelling that could result from the proposed changes. Consumers can trust products that have been given a Natural Product Number (NPN) by Health Canada. Under the proposed regulatory framework, consumers who have grown accustomed to this may encounter NHPs that have some form of licence number and others that do not. Our members have built their businesses on quality, safety and trust, and the proposed changes challenge each of these pillars. There are elements of the regulations that Health Canada should modernize, but they ultimately should not dismantle Canada s world-class regulatory system for NHPs in the process. The evidence needed for the approval and marketing of self-care products should reflect the product type and claims made, while traditional sources of evidence must continue to be accepted. If these steps are taken, they would be important strides in preserving the strength of our sector. Another component of the self-care products framework is the introduction of cost recovery for sites, applications and right to sell for NHPs. Cost recovery was expected to eventually be incorporated into our sector, as it was part of the original recommendations set forth by former Health Minister Hon. Allan Rock. As a maturing industry, we accept the purpose of cost recovery but, nonetheless, are concerned as a small sector that fees will have a significant impact. Recent consultations on updates to cost recovery for other consumer health and drug products show

fees as high as $30,000 for site licensing, $600,000 for product licensing and $4,500 for the right to sell. The NHP industry wants to accept the responsibility for the oversight applied to our products, but we have concerns with how a large-sum fee or fees could be detrimental to some small- or medium-sized businesses. To help NHP companies ease into the anticipated costrecovery regime, we propose that the government consider phasing in the cost-recovery model over four years, following the coming-into-force of updates to the existing regulations. We also request additional funding for the Natural and Non-prescription Health Products Directorate (NNHPD) to assist them with the implementation of tools to transition into a fully cost-recovered sector. The proposed regulations will put significant added pressure on that department, which may result in long-term pressures including increased costs for NHP manufacturers and distributors. Additional funding will help NNHPD to alleviate the pressure of these changes and ensure a smooth transition for the directorate and the businesses that rely on it. These steps will respect the extensive costs that will be taken on by these businesses and help develop a process that industry can fund moving forward. Maintaining the De Minimis Threshold CHFA represents more than 1,000 businesses across Canada that compete on a daily basis with companies around the world, especially with those headquartered in the United States. Many of our member businesses are small- and medium-sized enterprises that offer niche products to Canadian consumers with very small profit margins. U.S.-based online retailers have lobbied Canada to increase its de minimis threshold substantially, and they have pushed for the U.S. to adopt a similar bargaining position in the coming NAFTA negotiations. Our sector welcomes competition, but it is crucial that this competition happens on a level playing field. Canada needs a stricter de minimis threshold, as our online purchases more regularly come from outside of the country, sending Canadian money abroad while decreasing the tax revenues collected by government. This great expense comes with no benefit to the small- and medium-sized businesses that fuel the Canadian economy. NHP retailers, wholesalers and distributors are already concerned that consumers exploit an existing personal importation loophole that allows them to bring products into our country that have not been regulated by Health Canada. We have a world-class regulatory system that features pre-market approvals to ensure consumers have access to safe and effective products. It is therefore very concerning that, if incentives continue to tilt in favour of international online sales, more consumers will start taking advantage of this loophole, which could jeopardize their safety and create challenges for regulatory enforcement. We strongly recommend the continuation of the current de minimis threshold to ensure Canadians continue to have an opportunity to succeed and grow, and that incentive structures point consumers in the direction of effectively regulated products from those in the Canadian marketplace.

Support for Natural Health Products Research Funding New standards for scientific proof may arise from what is currently being proposed through the proposed self-care products framework. This could present a huge challenge for NHPs. While many products are rigorously supported by scientific evidence, the evidence requirements for NHPs reflect the fact that they have been used traditionally for thousands of years and are generally considered lower-risk. Additionally, since patentability of a natural substance is not widely available, this deters an NHP manufacturer from investing heavily into expensive clinical research. Innovators in the Canadian NHP sector are constantly looking for ways to improve their products. Developing new and patentable processes for extracting natural ingredients is one way they can create products that help Canadians achieve better health outcomes through self-care. Clinical research improves the reputation of Canadian businesses distributing their products domestically but also abroad, which brings more money to our shores. The lower patentability of NHPs makes it less desirable for many smaller producers to undertake more research. This issue could be remedied through funding for research that businesses would be able to apply for. The primary mechanism for health research funding in Canada is the Canadian Institutes of Health Research (CIHR).CIHR divides over $1 billion annually in research funding to investigator-driven research and priority-driven research. The latter refers to initiatives created by the Government of Canada to investigate pressing health issues that are of strategic importance to our country, and receives approximately 25 per cent of the funding distributed each year. While individual researchers can submit proposals to this stream, we propose that a small portion of priority-driven research funding be allocated annually to support NHP research. In 2018 2019, we propose that pilot funding of $10 million be contributed toward this initiative. This funding would create a strong foundation for improved products that will lead to lasting improvements in our sector, increasing the productivity and competitiveness of Canadian businesses in the global NHP market. Recommendations: To help NHP companies ease into the anticipated cost-recovery regime, we propose that the government consider phasing in the cost-recovery model over four years, following the coming-into-force of updates to the existing regulations. We also request additional funding for the Natural and Non-prescription Health Products Directorate (NNHPD) to assist them with the implementation of tools to transition into a fully cost-recovered sector. We strongly recommend the continuation of the current de minimis threshold to ensure Canadians continue to have an opportunity to succeed and grow, and that incentive structures point consumers in the direction of effectively regulated products from those in the Canadian marketplace.

We recommend that $10 million in pilot funding be made available in 2018-2019 to support priority driven research, within the Canadian Institutes of Health Research, be allocated annually to support research geared toward NHPs.