Natural Health Products Bill

 

 

 

 

We agree that the level of regulatory control of natural health products should be commensurate with the risks associated with their use. Evidence shows there is minimal risk associated with their use, so there should be minimal control.

 

Consumers do not need to be ‘supported’ to make informed choices about their use of natural health products. This is nanny state condescension. The internet has made personal research, to whatever depth, easy and affordable.

 

Our main suggestion would be to accept the status quo, which lets the public take responsibility for their own health maintenance by selecting from a wide range of safe supplements at the best prices i.e. if it ain’t broke don’t fix it. USA has had a fine system for many years along these lines. If a natural product causes problems e.g. Ephedra, it is simply banned. Misleading labeling, advertising etc is covered by existing legislation.

 

If the above suggestion is not accepted we would suggest the addition of the following Purpose: To foster and encourage an innovative, internationally competitive natural products industry.

 

 

 

In trying to define natural health products for regulation you are drawing arbitrary distinctions which will, for instance, include most cosmetics which contain functional plant extracts. Similarly having a ‘white’ list of permissible ingredients will inevitably exclude many useful or innovative products whose cost of registration and annual fees cannot be justified by the size of the NZ market.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Again this question indicates the arbitrary and artificial nature of the distinctions that are being drawn and the struggles of those from outside the natural health world to describe and delineate it, in an attempt to control it.

 

 

 

 

 

 

This loaded question presupposes the acceptance of a ‘white’ list of permitted ingredients; it indicates the agenda and prejudices of those who have drawn up this ‘Consultation Paper’ (and whom will presumably make up the ‘small unit’ of regulators). Some issues: it will be impossible for the regulator to stay current with the continuous development of natural product science; safety assessments by the regulator for any new ingredient will make many uneconomic to introduce to our small market; the regulatory incentive will be towards dinosaur companies with dinosaur products.

 

 

 

 

 

 

The structure/function claims allowed in USA (if supported by documentation) along with the standard disclaimer, have been show to work well. The Consultation Paper excludes out of hand claims about preventing or treating serious disease (regardless of the evidence) when it is well established that some simple supplements (folic acid, vitamin D) can do just this. The inbuilt assumption that only pharmaceutical products can be effective ‘medicines’ reveals again the background and prejudices of those who have drawn up the Paper, and the potential regulators.

 

 

 

Yes, provided the regulators are drawn from, and understand, the natural products industry and do not impose requirements from the pharmaceutical/medical industry.

 

 

 

We support greater clarity and consistency on supplement labels.  We suggest that the natural products industry could be asked to reach a consensus on consistent labelling standards.

 

 

 

Yes.

 

 

 

Don’t know.

 

 

 

Existing legislation covers misleading advertising. Legislating that the brand, uses, name of advertiser and ‘Always read the label before use’ go on every advertisement would not only disadvantage NZ distributors overseas and waste money on unnecessary policing; it is also insulting to the intelligence of the consumer.

 

 

 

You do not have to reinvent the world – it is okay at the moment – truly.

 

 

 

As above.

 

 

 

We export thousands of different products to many countries and it would be impossible for us to stay current with their ever changing standards, as proposed. We rely on the importing consumer or company to check their own country’s standards and our website carries a disclaimer to this effect. The proposed rule would make us completely uncompetitive with natural product exporters from Australia, USA and elsewhere.

 

 

 

As above. We have been carefully building our export sales for many years and any internal regulation or approval regime (for our 4000 different products?) would require us to shift at least our export operations offshore to remain competitive. Why would you even be proposing such a thing?

 

 

 

No. Again this question carries the implicit assumption that there is a problem that will be fixed by more rules. Has there ever been a NZ contamination scare? All you will do is add layers of non productive cost. All NZ manufacturers currently need to comply with the food manufacturing standards and most also with various GMP.

 

 

 

As above.

 

 

 

If you go ahead with this unnecessary regime, on product turnover or it would be likely be uneconomic to manufacture small or specialist lines (if they incur a set levy).

 

 

 

A percentage of turnover would be fair across the board. Of course it will disadvantage NZ manufacturers and cause export manufacturing to go offshore.

 

 

Anything over $500 and our smaller ‘own brand’ lines (approximately 12) would become uncompetitive internationally and would cease to be made. All lines are for sale in NZ and internationally.

 

 

Perhaps half paid by applicant; half by levies would be fair. The Consultation Paper is already flagging the likelihood of not being able to keep up with new product assessments, with the result that New Zealanders will lag behind in the availability of new ingredients and products. An inevitable consequence of over-regulation.