Natural Health & Supplementary Products Bill – Ministry of Health’s consultation paper ‘The Regulation of Natural Health Products’

Submission to: Ministry of Health
Submission Author: Philippa Jamieson and Marion Thomson
Friday, March 4, 2016

Submission on the Natural Health & Supplementary Products Bill
Ministry of Health’s consultation paper ‘The Regulation of Natural Health Products’

Natural Health Products
Ministry of Health
PO Box 5013
Wellington 6145

FROM: Soil & Health Association of New Zealand
PO Box 340002
Birkenhead 0746

4 March 2016


Re: the Ministry of Health’s consultation paper ‘The Regulation of Natural Health Products’

The Soil & Health Association of New Zealand Incorporated (‘Soil & Health’) is the largest membership organisation supporting organic food and farming in New Zealand, and is one of the oldest organic organisations in the world, formed in 1941. We are committed to advocating our maxim ‘Oranga nuku – Oranga kai – Oranga tangata’ meaning ‘Healthy soil – Healthy food – Healthy people’ and to creating an organic New Zealand.


The Soil & Health Association of NZ opposes the Natural Health Products Bill and requests that it be removed from the Order Paper.
Our opposition to this Bill includes the following reasons:


1.     The Bill would drastically reduce access to, and options for, safe and effective healthcare for New Zealanders.


a)     Natural medicines have been used safely and effectively for thousands of years. The Bill would, however, ban numerous natural health product ingredients without just cause. Some of these ingredients could in fact be everyday foods with a long history of safety.

b)    The proposed regulations would severely limit health options for consumers by allowing only a very limited number of permitted ingredients on a ‘white list’.

c)     The limited ‘white list’ approach would mean that many safe and effective natural health ingredients would become illegal.

d)    Many of the ‘white list’ ingredients have severe dosage and application restrictions placed on them. There is no scientific or medical justification for this, and no history of risk to human health.

e)     Soil & Health asks that the current, sensible ‘black list’ approach is retained, so that natural health products are ‘innocent until proven guilty’. If they are shown to cause harm, they are banned and added to the black list.


2.     The Bill would severely affect natural health practitioners, who would be robbed of numerous safe and effective health products to recommend to their patients. This would limit or destroy their businesses, as well as impacting on their ethical duty of providing the best care for their patients.


3.     The Bill would severely affect New Zealand natural health producers and suppliers, driving many small-to-medium enterprises out of the market.


a)     The Bill introduces significant new compliance costs on New Zealand businesses to prove that a natural health ingredient to be safe so it can be added to the proposed ‘white list’.

b)    The compliance costs for businesses go well beyond proving that an ingredient is safe. Costs include notifying the regulator about each ingredient, paying annual fees, providing information about health benefit claims, obtaining a licence to manufacture the product, and complying with the Code of Manufacture Practice. The sum total of compliance costs will be out of reach of many businesses as it could reach into the tens of thousands of dollars or even more.

c)     Businesses will not be able to provide as great a range of natural health products, for sale in New Zealand, or for export.

d)    The only manufacturers likely to be able to survive will be the larger ones.

e)     If consumers are unable to find the products they want in New Zealand they will buy online and import them, therefore bypassing our local industry.


This is a Bill whose only benefits are for large and/or multinational companies who can afford to stay in business under this regime, and for the pharmaceutical industry. The primary goal of health legislation or regulation must be the health of New Zealanders. However this Bill does nothing to improve people’s health – in fact it will worsen the health of New Zealanders, as we would lose numerous safe and effective healthcare options.



Soil & Health asks that the Bill and associated proposed regulations be abandoned.

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