What to do as a consumer?

For Health Canada we are all consumers, this is this point of view to which they will pay attention.

The Quebec herbalist guild invites you to participate in the Health Canada consultation, directly on their site. Postal letters are also possible. This consultation takes place in 5 questions.

You can use the answers that the herbalist guild offers you. (see below)

Context of questions

1. For the first 4 questions

It's up to you to adapt the text to your reality.

• In daily life: family, herbalist, naturopath, therapist, craftsman, gardener, seed, traditionalist, manufacturer ...
• In the economy: small business, company, consumer, distributor, buyer, user, trader, client ...

2- For the 5th question; It's your experience.

Your letter is part of question 5 of the public consultation. We invite you to positively share your personal experience in connection with the use of natural health products (PSN).

We want to provide solutions and aware of the impacts of a lack of access to the PSNs, and not put us on any employees. We suggest reflection tracks to positively formulate your message.

To participate: click on this link

(Copy your answers to the spaces provided inthe question sheet)

https://www.canada.ca/fr/sante-canada/programmes/consultation-frais-proposes-produits-sante-naturels.html#a1

Direct link to the form https://healthcanada.qualtrics.com/jfe/form/SV_6S9O1Idu8CNj7Tg?Q_Language=FR-CA

To send by post (only print the 5 pages of your answers)

Question 1

Please tell us about your comments on the structure and amount of the rights offered.

Here is the proposal of the costs in summary:

Health Canada cost recovery offers initial and annual costs:

Annual site license: which can be around $ 50,000 to have the right to produce, pack and label herbalist products, by building. The initial cost of NPN can vary between $ 1000 and $ 8,000. The annual NPN sales rights are $ 542 per #, a herbalist company has hundreds of NPNs, making it unrealistic ($ 55,000 per year).

Suggested answers (adapt the responses to your context if necessary.)

• Unrealistic costs for SME companies whose financial model is similar to the financial models in the agricultural field. The beneficiary margins are very different from pharmaceutical companies.
• $ 542 of annual fees per NPN is too much, for manufacturing businesses in herbalism, the NPN number makes this impossible for the financial model.
• As it stands, the subsequent costs to the buyer will decrease the capacity of consumers to obtain PSNs and reduce my ability to self-care.
• I suggest that you create a category of costs for herbalist companies since their business model is different from that of pharmaceuticals.
• $ 58,000 for an innovative or leaving product from the definition of monographs will suffocate innovation in Canada, I want herbalist companies to meet variable needs.
• Why not consult professional associations to facilitate your evaluation of PSNs?

Question 2

Please tell us about your comments on the service standards offered and penalties in the event of non-compliance with standards.

Here is the proposal of the standards and penalties in summary:

An offender company can have a fine of $ 5 million a day to be in violation. Our opinion, honest natural health companies are absolutely cooperative for market withdrawals and have the health of Canadians at heart

Suggested answers (adapt the responses to your context if necessary.)

• I agree that Health Canada has the tools to control companies that neglect Canadians' health.
• Health Canada could consult Canadian professional associations to help develop quality standards.
• I have confidence in my local businesses to do everything possible to comply with standards.
• I never had serious opposing reactions using herbalist natural products.

Question 3

Please give your opinion on the proposed mitigation measures, including for small businesses.

Here is the proposalmitigation measures In summary :

Health Canada offers companies with less than 100 employees or whose turnover is between $ 30,000 and 5 million per year.

Discounts:

• 1st free NPN, the following full prices (for a company that can have 100 NPN)
• Site licenses: 25% of 50,000 discounts is still $ 3,7,500
• Annual sales rights: 25% discount, if 100 NPN: $ 40,650
• It is unrealistic compared to the business model and it does not take into account the economic value of these companies in their community.

Suggested answers (adapt the responses to your context if necessary.)

• A local producer, who packs, label and distributes local, will have a more positive impact on the Canadian economy than a company that is content to import and subcontract its other activities with other license holders.
• The proportion of local wages directly impacts the Canadian economy.
• An importer of PSN has a much lower proportion of local expenses and generally takes advantage of the international market to create larger margins of profits, approaching the pharmaceutical model.
• The contribution measure to the local economy as well as the agricultural financial model should be taken into account in the following proportion: 85% attenuation for local producers and 25% attenuation for importers.

Question 4

Please give your opinion on the calendar offered for implementation (1er april

2025).

Here is the calendar proposed in summary:

Health Canada want their cost collection structure to be in action on April 1, 2025.

Suggested answers (adapt the responses to your context if necessary.)

• The deadlines are very short, particularly in a context or the field of PSNs is in recession, Canadian retailers and producers already have difficult years.
• It would be more judicious to wait for the market to make an economic recovery.

Question 5

Please provide any other comment relating to the price proposal.

For your information: formulate your testimony

Tracks of reflection to write your letter:

• Health Canada is very sensitive to the self-care capacity of Canadians.
• Health Canada wants to know how economical you are for the provincial health system.
• What would be the impacts on your health if you no longer had access to your PSN and your use of the local health system?
• What will be the impacts of the increase in PSN prices on your personal or family consumption? Your auto-socket capacity.
• What will be the impacts, for the operation of your business, the increase in the costs of recovery of each of your products (herbalist, naturopath, distributor, manufacturer, shopkeeper ...

Writing advice:

1. Stay neutral or positive in your writings
2. Suggest solutions
3. Health Canada will remain deaf to criticism or judgments in this regard, you may see your contribution excluded. Have you read again if necessary.
4. We invite you to positively share your personal experience in connection with the use of natural health products (PSN) in the text box of question 5.

The guild of the herbalist from Quebec we are preparing an explanatory video. You will find the information and links that make up this text.

Here is the link :https://guildedesherboristes.org/pages/message-important-concernant-les-produits-de-sante-naturels-action-a-prendre-rapidement

THANK YOU FOR YOUR COLLABORATION!

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