Facts about Product Label Changes
Health Canada has been consulting on a self-care framework that includes Natural Health Products (NHPs) for a number of years. In February 2018, they introduced a phased-in approach. The first phase includes updating the NHP Regulations, to include Plain Language Labelling (PLL).
What is Plain Language Labelling?
When originally proposed, PLL sounded reasonable. It was intended to:
- Improve label understanding and clarity;
- Provide a standardized outer label to help find important information; and
- Provide modern contact information to easily report problems and adverse reactions.
Unfortunately, PLL has become much less reasonable. With a lack of flexibilities for formatting and font size, it poses potential risks to Canadian businesses and consumer health.
Additionally, no clear evidence has been identified by the government to support PLL. When you don’t know what you’re fixing, you are destined to waste time, money and take on the risk of introducing new concerns.
As a direct result of PLL, there will be fewer NHPs available, and what will be available, will be more expensive. Important warning information will be moved from its current place on the label to peel-back labels, removable labelling, online, or in other electronic formats. Furthermore, there is no plan in place to educate the public on these changes.
Labelling Changes - the impact on our sector and others
The below image illustrates the numerous labelling changes that are ongoing simultaneously. It is precedent-setting to make all of these changes at once. Rushing an initiative that will change the face of all NHPs in Canada can be confusing to consumers, will cost industry millions of dollars and could undermine the current positive trends in self-care. Click here for more information.
Implementing PLL will require time, resources and funding to redesign, reprint, repackage and reship all NHPs on the market – a great detriment to the environment and financial burden for a thriving industry. A preliminary estimate shows that this proposal may cost a sector, composed primarily of small to medium-sized businesses, upwards of $1 billion.
With a price tag this steep, there should be clear evidence to support its benefit. We continue to urge Health Canada to pause the rapid progression of PLL and re-evaluate. We need solutions that help consumers and allow businesses to continue growing.