On March 1, 2011 Health Canada begins full enforcement of NHPs. Here are the details:

• March 1, 2011 - retailers will not be permitted to purchase unlicensed stock from suppliers (EN or NPN is required), regardless of a submission being in queue.

• March 1, 2011 - importers will not be allowed to import unlicensed products (EN or NPN required).

• September 1, 2011 - retailers will not be allowed to sell to consumers any product that does not have an EN or NPN. In other words, retailers will be allowed to continue selling out unlicensed stock from now until September 1, 2011—but after September 1, 2011 they will not be permitted to sell unlicensed stock.

This is a drastic sea change in policy, and I need to emphasize with all of you that this is no small matter. I strongly encourage for those of you who are CHFA members to send your feedback to Helen Sherrard (hsherrard@chfa.ca) and let them know how you feel. They need feedback.

So that you are aware, a strong cross-stakeholder advocacy initiative is already under way—and I will be sending out invites to participate over the next month. We cannot afford to lose our innovative products, especially when Health Canada is not committed to changing their evidence standards.

The NHPD has also told us they are committing to changing some of their evidence standard guidelines. But I need to emphasize here—and I have learned this just on December 10, 2010—that none of those evidence standard changes are with regards to how much/what type of evidence is required for what type of claim (i.e., this is our biggest challenge as always). While there are some minor changes that will be beneficial, for the most part these evidence standards have turned out to be minor and have been watered down by Health Canada.

You cannot bank on an advocacy change—if you intend to sell any products after March 1, 2011 then you need to have your submissions in now.

Brian Thomas Wagner is president of NHP Consulting Inc.

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