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  • Writer's pictureSarah

Submission Example for the Therapeutic Products Bill

Here is a template that you may find useful to help guide your submission if you are struggling with what to write. Many have reach out asking for help. Feel free to take out bits not relevant to you and adjust to make it your own.

You can submit your submission here, but make sure it is done before this Sunday 11.59 pm.

As a user of natural supplements to support my health, I oppose the Therapeutic Products Bill in its current form, as it will likely negatively impact small businesses, consumer access to Natural Health Products (NHP), the way natural health practitioners work, and freedom to share natural health information.

The proposed Bill in its current state lacks detail and applies a one-size-fits-all approach to NHP. I support the need to ensure the safety and quality of NHP, but the Bill is not fit for purpose for the following reasons:

  • There is no clear process, timeframe, or cost to get approval for NHPs. The additional red tape proposed will no doubt raise the cost of natural health products for the consumer, making preventative health more of a luxury.

  • The proposed approach of individually approving each ingredient used in NHPs is an unnecessary administrative burden given the low-risk nature of many NHPs.

  • The Bill proposes to regulate all therapeutic products under a single regulator appointed by the Director-General of Health (Clause 330). The regulator is given a lot of discretionary powers, and it is unclear if they will have experience in the area of natural health, which is important as they may be determining which products are safe and effective for natural health users.

  • The Bill provides the framework without the detail, so the regulator will be able to implement secondary legislation without the necessary checks and balances, leaving many unknowns.

  • Unlike current legislation where the responsibility lies with the business to be able to back up claims, under the proposed bill, it will lie with the regulator, and only approved statements about the benefits will be allowed to be expressed by individuals, natural health practitioners, and businesses. If they make a claim not permitted by the regulator, it could result in a fine of $200,000 or 5 years in prison (Clause 192 & Clause 252). This is a huge concern for freedom of speech.

  • It is unclear how the Bill will impact other traditional medicines, such as Rongoā Māori, as many of the medicinal herbs they use will need to be individually approved, adding an unnecessary burden to their work.

  • There is no indication that there will be an independent review of research provided by a company to get their therapeutic products approved. We’ve seen many times where a company’s own funded research will be particularly biased and cover up the risks or limitations in the product.

There are better approaches to ensuring the safety and quality of natural health products that do not require broad sweeping legislation, as proposed in the Therapeutic Products Bill. Most OECD nations regulate low-risk, natural form products alongside food, which is similar to what we currently do.

Let me know if this is useful! If you want an example of a more detailed submission, I encourage you to checkout Healthpost’s draft one here.

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