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For NHPs cost recovery is proposed to include fees for regulatory activities such as product evaluation, site licenses and annual renewal fees.  

With the establishment of the Natural Health Product Regulations in 2004, NHPs have not been subject to cost recovery. We understand cost recovery is a necessary part of doing business in Canada however, Health Canada, did not do a proper economic study and didn’t consider that GST is collected from the sale of NHPs.

Currently, the foundation of our regulatory system is stretched to the brink with massive backlogs in product applications. In short, data used to establish this current program is dramatically flawed and the proposed fees will financially decimate the NHP industry in Canada.

The timing of implementing this program at the same time as new labelling requirements will financially decimate many companies in our industry, making it extremely challenging for them to stay viable. These regulatory changes are unfair, unrealistic, and so costly they will force many small to medium-sized businesses to shut down Canadian operations.

On-going US-Canada Trade Relations 

The economic landscape has shifted considerably with the imposition of new U.S. tariffs and Canada’s announced retaliatory measures. These trade actions will place additional financial strain on Canadian businesses, exacerbating the challenges industry already faces with burdensome red tape.  If cost recovery is implemented as proposed, it will compound these pressures, making it even more difficult for Canadian companies to remain competitive in their own market.

It’s critical that Health Canada and the Minister of Health understand that moving forward with cost recovery would directly undermine the ‘Team Canada/ Canada First’ efforts, imposing further financial burdens at a time when businesses are already grappling with rising costs and trade barriers. Regulations already make it easier, and more cost-effective for US brands to enter the Canadian market, making it even harder for Canadian brands to stay competitive.