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Mackie Vadacchino

44th Parl. 1st Sess.
October 30, 2023
Context: Department of Health's Regulatory Changes for Natural Health Products Committee Business (HESA) - Oct/30/23
Ms. Mackie Vadacchino (Chair and Administrator of Boards of Directors, As an Individual)
  • 11:03:52 a.m.
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I would like to start by thanking the committee for this opportunity. Industry representation is needed, not only so that we can tell our side of the story, but also so that we can properly correct the mistruths and damaging statements made by Health Canada. My name is Mackie Vadacchino. I am a proud Quebecer and an active member of the Montreal-Italian community. I have been working in the natural health products industry since 2004 and currently sit on the board of several companies in the industry after 15 years as the CEO of Bioforce Canada Inc. Over the course of my career, I have been involved with many changes from Health Canada on which we worked together to obtain mutually beneficial results. I must say that this time, in addition to the negative financial and environmental impact, what we found most difficult to accept was the total disrespect for our industry, for our businesses and for us as Canadian citizens. I must stress that the impact is massive and costly on several levels, and will place a financial burden on the supply chain, which is essentially comprised of small natural health product or NHP manufacturers and providers. And let's not forget our local retailers. In Quebec, supporting local businesses is a matter of pride. Sadly, the implications of these changing regulations will be felt in almost every small local NHP store, which will see a number of products disappear from their shelves. The impact will be costly in terms of jobs across the NHP ecosystem, the financial stability of small businesses and the mental health of industry members suffering from stress. Prices are projected to increase by 30 to 35% as costs get handed down to the consumer. There will also be an environmental cost, which is a major concern for our industry. The new labelling rules that will come into effect in 2025, a mere two months after the proposed cost recovery fees, will require the use of a peel-back solution for most products, which renders the entire container non-recyclable or will force manufacturers to increase the size of the packaging to accommodate the new mandatory format. All NHP manufacturers in Canada will be forced to dramatically increase their environmental footprint. The guidance for the new labels is inflexible, outdated and out-of-touch. Our industry is built around natural products. Our ingredients are born of the Earth. We cannot disregard the environmental impacts the new labelling laws will have. The new font requirements will also make reading the French and English labels much harder to understand, as hosting two languages on the same size packaging will be extremely challenging for many NHP products, due to the multiple ingredients listed. Perhaps a QR code or a smart label could be considered here. Let's talk about cost recovery. The proposed cost recovery fees are so high that even with the proposed small business mitigation scheme, many small businesses will simply not be able to afford to bring any new product to market. Canadian innovation in the industry will be stifled. We are asking Health Canada to reassess the application fees to encourage industry to be compliant, but also to allow Canada’s NHP system to remain the most respected in the world. The Canadian NHP industry also faces fierce competition from our US neighbours, who market and promote dietary supplements to Canadians online. These US products are not regulated, and American law regarding health claims made for products differ greatly from Canada’s. The majority of Canadian NHP companies are not against regulations, but if these regulatory changes are truly about the health and safety of Canadians, then we desperately need regulations that take into account the many challenges and realities the sector faces in today’s day and age, the size of the businesses that make up the majority of the industry, and the need for innovation that will continue to allow Canadian industry to offer natural, low-risk products. This industry should and can thrive under the self-care framework, and I am honoured to be here today to offer insights that can be useful and productive. Thank you for having me.
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