Health Canada regulates natural health products (NHPs) so that Canadians can have confidence that the products they use are safe, effective, and of high quality. Labels are an important tool to assist Canadians in making informed health choices when selecting and using NHPs.
Health Canada has amended the Natural Health Products Regulations to make NHP product labels easier to read and understand. These changes support consumers in selecting and safely using NHPs. For more information and to access the supporting Labelling of Natural Health Products guidance document, visit What’s New: Natural and non-prescription health products.
Under the Natural Health Products Regulations, which came into effect on January 1, 2004, natural health products (NHPs) are defined as:
- Herbal remedies
- Vitamins and minerals
- Homeopathic medicines
- Traditional medicines, such as traditional Chinese medicines
- Other products like amino acids and essential fatty acids
Choose “other end uses” as the commodity use designation when importing.
The Automated Import Reference System (AIRS) is a reference tool that shows the import requirements for Canadian Food Inspection Agency (CFIA) regulated commodities. AIRS is a Canadian Food Inspection Agency (CFIA) tool that utilizes a series of questions to determine the admissibility requirements of animals, plants, and food items.
The Canadian Society of Customs Brokers (CSCB) recently initiated an inquiry for a natural health product, and ARGO Customs (as a corporate CSCB member) wants to share this information as you may find the answer beneficial when using AIRS.
Q: Natural health products are not regulated as food, yet when using AIRS and selecting “for human consumption,” the requirement for an SFC licence is listed. Why is this occurring?
A: In fact, there are products that are for humans to consume per se (e.g., NHPs), for which brokers should not be selecting “for human consumption.” We typically say that “for human consumption” is reserved for foods subject to the licence requirements of the Safe Food for Canadians regulations.
Although NHP are technically for humans to consume, you’re correct that they aren’t regulated as “food” and so “for human consumption” shouldn’t be used. Maybe the best advice I can give is to think about it this way:
- If the commodity is regulated as a food under the SFCR and is not subject to any exemptions or exceptions, choose “for human consumption.”. The Conditions of Import in AIRS for “other end uses” list these exemptions/exceptions.
- If the commodity is regulated as a food under the SFCR and is subject to an exemption/exception – choose “other end uses.”
- If the product is consumed but not regulated as a food (e.g., NHPs, pharmaceutical products), choose “other end uses.”
Forms, templates, and guidance documents from Canada.ca:
- Natural Health Products Online System – natural health product application forms and guidelines
- Natural Health Product Licensing – Forms and templates
- Natural Health Products Site Licensing – Forms
- Clinical Trials – Forms and templates
- Guidance Documents – on all aspects of regulatory requirements for natural health products
- Guidance for Industry on Third-Party Issuance of international Trade Certificates
The CSCB (Canadian Society of Customs Brokers) actively seeks and achieves improvements in government policies and procedures on behalf of our members and their clients and consistently delivers relevant, high quality products and services, including education and professional development. The CSCB creates member value and benefits through education, advocacy, information, and innovation.
If you or your business need assistance with these import regulations, please do not hesitate to contact ARGO Customs Brokers. ARGO is always available for consultation regarding importing into Canada and exporting globally.