The Government Proposals for a Natural Health Products Bill may limit consumer access to natural health products.

The NZ Society of Naturopaths has a number of concerns about the proposed Natural Health Products Bill. The NZSN says We would like to see regulations which protect the public; but the bill in its present form is likely to restrict consumer choice and increase costs of Natural Health Products.

NZ Society of Naturopaths Supports
Some form of regulation for natural health products
A list of prohibited ingredients
the concept of a consultative body and would like to offer a representative
The use of Therapeutic Claims; provided these are backed up by evidence and are auditable. The NZSN see no reason to limit the therapeutic claims to a low level claim for minor conditions.
The proposed clear and informative labelling and advertising requirements
A code of practice for the manufacture of natural health products

NZ Society of Naturopaths Objects to
A list of permitted ingredients
Only Low level therapeutic claims being allowed; provided there is evidence any level of therapeutic claim should be allowed.
The costs that the bill in its present form would incur; especially in respect to the impact this would have on small business, innovation and ultimately the consumer

NZ Society of Naturopaths Suggests

No regulation for Homeopathic remedies, tissue salts, flower essences, herbal teas and natural food state products and individual client preparations (e.g. herbal medicines) made by any registered natural health practitioner [only Traditional Chinese Medicine & Rongoa Maori are specifically named in the present proposal.]
Management of appeals and dispute resolution by a Review committee which would be effective and more cost effective than a court system

The new Bill proposes a list of prohibited ingredients and a list of permitted ingredients.
The NZSN fully supports a list of prohibited ingredients and sees this as important for public protection from dangerous substances. However, the permitted ingredients list poses some problems say the NZSN, as the proposed list does not include many safe products available in NZ today.

The proposed bill suggests that companies seek approval for their ingredients to be added to the list. However, the NZSN points out that the suggested form of approval would be a lengthy and costly process. The whole process may mean many small businesses do not survive and those that do will have to pass on costs to the end consumer.

In addition, the NZSN believes that some Natural Health Products should fall outside the regulations. These products do not easily lend themselves to any system of lists of approved substances; such as Homeopathic remedies, tissue salts, flower essences, herbal teas, natural food state products and individual client preparations, (e.g. herbal medicines) made by any registered natural health practitioner. [Only Traditional Chinese Medicine & Rongoa Maori are specifically named in the present proposal.]
The NZSN has concerns about the proposal allowing only Therapeutic claims that are of a Low level such as minor conditions. Provided there is evidence, any level of therapeutic claim should be allowed according to the view of the NZSN.

The costs that the bill in its present form would pass on would have a very negative impact on small business believes the NZSN. Some may not be able to continue trading both in NZ and exporting to other countries. The costs in gaining product approval would also deter innovation for new natural health products. Ultimately the consumer would have less choice and higher costing products.

The NZ Society of Naturopaths urges everyone who has an opinion on the proposed Natural health Products Bill to make a submission to the Ministry of Health. The Closing date for submissions is 17th May 2010

The Development of a Natural Health Products Bill: Consultation Paper is available at the Ministry of Health website: http://www.moh.govt.nz/moh.nsf/indexmh/ ... bill-mar10
For information on the NZ Society of Naturopaths, go to http://www.naturopath.org.nz.

CLICK HERE to Read about the updates to this proposal (June 2011)