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CHPA response to new labelling requirements for nosodes – August 6, 2015:

On July 31, 2015, the Minister of Health announced new labelling requirements for nosode homeopathic medicines, incremental to the labelling requirement implemented in September, 2013 to include on product labels the statement:

“This product is not intended to be used as an alternative to vaccination.”

bottleandleavesHomeopathic medicines that are nosodes, licensed and marketed in Canada in 2015, are compliant with this labelling requirement and the provisions of the Natural Health Product (NHP) Regulations as evidenced by 8-digit product license numbers preceded by DIN-HM. DIN-HM on the label clearly indicates the product is homeopathic as opposed to other natural health products or drug products.

CHPA has supported Health Canada’s efforts to make consumers aware that nosodes are not intended for use in immunization, posting a statement to this effect on the association’s web site in March of 2013, closely following NNHPD’s consultations held in January and February of 2013 (click here). CHPA released this position statement months in advance of Health Canada’s formal notification to product license holders of the required labelling change. Since that time, CHPA has worked constructively with NNHPD to assist in responding to the expressed concerns of provincial/territorial medical officers of health and the Public Health Agency of Canada regarding off-label use of nosodes as alternatives to conventional vaccinations.

The new statement that Health Canada has requested to appear on homeopathic nosodes products by January of 2015 is:

“This product is neither a vaccine nor an alternative to vaccination. This product has not been proven to prevent infection. Health Canada does not recommend its use in children and advises that your child receive all routine vaccinations.”

CHPA was not consulted in the development of this new labelling statement and has expressed concerns to Health Canada about the lack of consultation and the feasibility and timing of implementation. CHPA will encourage Health Canada to conduct the appropriate level and process of consultation before final implementation of this important policy decision.

Last modified: 07.31.2015
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