Health Canada's trying to over manage supplements (instead of focusing on the real harm within the system)

 Health Canada is looking for feedback, I urge you to write them an email about their new draft proposal regarding natural health products. 
Email: nnhpd.consultation-dpsnso@hc-sc.gc.ca

The draft they want to push through is here: https://www.canada.ca/en/health-canada/programs/draft-consultation-quality-natural-health-products-guide.html

Here's the letter I sent to them:

I am writing to provide my feedback on the Draft Revised Quality of Natural Health Products Guide.

First, I want to acknowledge that I appreciate certain updates, particularly the revised limits forelemental impurities.

However, I must express my deep concern that the remainder of the draft represents a significant and unnecessary overreach. The expansion from  46 pages to 132 pages reflects a heavy-handed approach to products that are, in many cases, simply packaged plants and vitamins. While I understand the intent to ensure quality, the burden imposed by this new framework (particularly the extensive new requirements for analytical method validation, dosage-form-specific performance testing, and lifecycle quality management) is disproportionate to the inherent risk profile of most natural health products .

The draft's demand for "substantially stronger scientific justification and supporting evidence" for quantification and other quality attributes is, in my view, a largely pointless exercise. Industry will simply fund studies designed to support their products, rendering the exercise a box-ticking bureaucratic hurdle rather than a meaningful safeguard. A prime example of this dynamic is the International Life Sciences Institute (ILSI). Founded in the 70s by a former executive of Coca-Cola and heavily funded by food and beverage corporations, ILSI is essentially an industry front group. It has been documented to have "infiltrated government health and nutrition bodies around the world" to push pro-industry content and defend controversial ingredients. If even the World Health Organization's expert panels can be influenced by such groups, it is naive to believe that requiring "stronger" industry-funded evidence will yield anything other than industry-favorable results. This new requirement will not improve public safety—it will simply add cost and complexity while being gamed by those with the resources to do so.

Beyond the futility of these evidentiary demands, the entire document feels like an unnecessary tightening of a framework that previously allowed for reasonable freedom. Natural health products are fundamentally different from pharmaceuticals. They are often traditional preparations with long histories of safe use. The previous framework struck a reasonable balance; this new draft tilts too far toward a pharmaceutical-style quality regime that is ill-suited to the nature of NHPs. I would rather see a return to the flexibility that existed previously, where the emphasis was on the licence holder's responsibility without micromanaging every aspect of quality through prescriptive guidance.

Finally, I want to share a personal perspective that informs my concern. When I suffered a tick bite and the conventional medical community left me with persistent symptoms and no further treatment options, it was the naturopathic community that provided a lifeline. When faced with unconventional health issues for which no mainstream solution exists, the natural health products arena is not merely a convenience, it is an essential resource. The additional regulatory burden proposed in this draft threatens the accessibility and diversity of these products, potentially closing off options for Canadians who, like me, have nowhere else to turn.

I urge Health Canada to reconsider the scope of this draft and to scale it back significantly. The impurity limit updates are welcome; the rest is over-governance that will harm access without meaningfully improving safety.