A look at the proposed NHP fees.

There’s never a shortage of subjects deserving space in our insights column – and the Canadian Health Food Association (CHFA) newsletter helped us pinpoint this week’s topic.

Health Canada is the federal department responsible for evaluating natural health products (NHPs) before they’re approved for sale, monitoring products once they’re on the market, and overseeing compliance and enforcement. Health Canada recently proposed implementing cost recovery fees for NHPs sold in Canada as a way to recoup costs incurred in its regulatory activities, and set out new mandatory fees for NHP product licence applications, site licence applications, and annual right to sell NHPs. Proposed product licence fees range between $1,124 to more than $58,000 depending on product category, while proposed annual site licence fees vary from under $5,000 to more than $40,000 (again, depending on the category). The cost recovery scheme – and labelling changes for NHPs – is set to come into force on June 21, 2025.

The announcement hasn’t gone down well within Canada’s natural health community. As per Gowlings WLG’s own analysis:

…there is risk that small and medium-sized businesses will not be able to afford the fees and it remains to be seen how companies will manage the costs. As a result, the proposal may result in Canadian consumers ordering more non-compliant product from outside of Canada, making it more difficult or impossible for companies who currently invest into Canadian compliance to continue doing so.

Gowlings WLG

A recent statement from the CHFA indicated that “One in five brands say they are seriously considering leaving the Canadian market due to increased regulatory complexity and financial burden,” as per CHFA President & CEO Aaron Skelton.

Health Canada’s proposed changes and full fee schedule can be found here. The consultation period is open until July 26; click here if you would like to submit feedback. We’re watching events in this sector, so visit this site often to stay apprised of industry updates.


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