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Read the latest newsletter below
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Dear Colleague,
The closing date for making submissions to the Ministry of Health on the Natural Health Products Bill is today (Friday 4 March) at 5 pm.
We hope many of you have been able to make a submission opposing the Bill.
- If you haven’t yet had time to prepare a submission and would like to, click here to send a pre-prepared one.
- For your information, the NZHT has now filed its submission. If you are interested, click here to read it.
If anyone hasn’t received this email directly from us and would like to be added to the list, please click this link Subscribe me to your newsletter list
Kind regards
Dave Sloan
dave@nzht.co.nz
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Make a submission to the Ministry of Health by 4th March 2016 |
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Introduction
The natural health product industry is facing a significant threat to its viability in the form of the Natural Health Products Bill.
As many will know, from around 2003 to 2008 industry and consumers successfully lobbied to prevent natural health products being regulated by an agency to be known as the Australian New Zealand Therapeutic Products Agency (ANZTPA).
In 2007 I was told by Tony Ryall (then National MP) to get industry to develop an agreed model of regulation for natural health products and to go back to him when he was the Minister of Health with a proposal. After enormous amount of time, effort and cost, a Joint Industry Proposal (JIP) was completed (as promised) and provided to government in February 2009.
The JIP is a simple notification scheme of products and ingredients that permitted verifiable claims to be made and adopted a risk-proportionate approach to the manufacture and sale of products.
The expectation was that once National was in Government, a model of regulation based on the JIP would become law within the first 100 days.
This did not happen and the Natural Health Products Bill (introduced in September 2011) bears no resemblance to the JIP. Rather it looks very similar to the Australian scheme that so many fought so hard and so long against.
The Bill is bad regulation and will damage industry and consumer choice
The Bill is draconian and heavy-handed legislation and fails to take a risk-proportionate approach to what are very low-risk products. It imposes significant new compliance costs on industry with no commensurate health or safety benefits to consumers.
The Bill is essentially a combination of the existing New Zealand restrictions with the worst of Australian and Canadian systems.
A product can only be lawfully sold if every ingredient in it is on the permitted substances list. Every product must be notified (annually and on payment of a fee) to a new regulatory agency known as the Natural Health Products Regulatory Authority. The Bill restricts the types of claims that can be made, and requires that information about health benefit claims are available on an internet site. The Bill requires all manufacturers to be licensed and to comply with a Code of Manufacturing Practice.
The Minister of Health has claimed that the Bill is a “light touch” and regulation proportionate to risk. He is wrong.
A light touch regime would not require common ingredients such as water, safe flavourings and additives used in every day foods to be approved by a regulator. A “light touch” would not require approval for a particular type of honey. The proposed list of permitted substances includes manuka and kanuka honey but no other types of honey.
A number of products will inevitably be required to come off the market once the Bill is passed because not all their ingredients will be on the permitted substances list.
This Bill is a text-book example of nanny-state legislation and is the type of “loopy law” that Paula Bennett is trying to get rid of.
NZHT has at its own expense obtained independent reports from TDB Consulting and Castalia about the economic and regulatory impacts of the Bill. These independent consultants confirm that the Bill is inconsistent with good regulatory principles, and imposes significant and unjustified costs on the industry. Click here for copies of the economic impact reports.
Make a submission to the Ministry of Health by 4th March 2016
The Ministry of Health is consulting on certain aspects of the natural health products regime that are to be contained in regulations. Submissions are due by 4th March 2016.
Because the Bill has not been passed into law this consultation process is an opportunity to tell the Ministry that the Bill needs be binned.
Click here for further information about the effects of the Bill and how you can make a submission on the draft regulations.
Pre-prepared Submission
For those who have limited time to prepare a submission and wish to oppose the Bill in principle,
click here for a short pre-prepared submission.
Contact MP's about your concerns, click here for a facility and some pre-prepared wording.
Please send this email on to other interested industry members and or consumers.
If you are not the correct recipient in your organisation, please forward this email to the appropriate person.
If anyone hasn’t received this email directly from us and would like to be added to the list, please click this link Subscribe me to your newsletter list
Kind regards
Dave Sloan
dave@nzht.co.nz
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