Red Tape Reduction Initiative – Impact on Natural Health Products

The Red Tape Review was announced by the Secretary of the Treasure Board in July 2025. This cross federal government initiative “requires all departments to review their regulations and propose measures to eliminate burden, such as removing outdated rules, reducing duplication with provincial regulations, and streamlining processes”. Red Tape is defined as “unnecessary and overly complicated regulations” and this review is intended to “support economic growth, improved efficiency, and make it easier for Canadians and businesses to interact with government services”.

In response, Health Canada and the Public Health Agency of Canada published a report presenting 42 applicable initiatives either completed, almost completed or that should be completed in the next 2 years. More information about the Health Canada/PHAC report can be found at: https://www.canada.ca/en/services/health/publications/health-system-services/report-red-tape-reduction.html

What are the principles of the Government of Canada Red Tape Reduction Initiative?
The Red Tape Reduction is centred around primary themes:
• increasing international alignment and reducing trade barriers;
• improving stakeholder experience and service delivery;
• supporting risk-based regulating;
• streamlining regulations, simplifying rules, and enhancing flexibility; and
• enabling new products and technologies.

What is proposed for Natural Health Products (NHPs)?
Regarding NHPs, Health Canada has committed to reducing regulatory burden by introducing a registration process, and adopting a flexible, risk-based approach to monitoring.

Though a work in process, central to the red tape reduction initiative proposed by Health Canada, is to move from the current licensing process for NHPs to a new approach that would replace existing attestation processes for high certainty NHPs such as products with a long history of use and/or where supporting evidence is clear, with a registration process. This new registration approach would apply to products completely supported by monographs (currently considered Class I) with the possibilities of including NHPs with higher certainty around appropriate evidence within the current Class II category.

In addition to the creation of this new registration classification, Health Canada is exploring flexibility for labelling requirements as well as ensuring appropriate safety monitoring for these low-risk products.

Are there any more details about the proposed registration process?
Nothing has been finalised. What we do know from Health Canada is that this new registration pathway will:
• Apply to “higher certainty” products with all other NHPs following the existing system;
• Replace the current administration of attestations with less administration of registrations while still relying on Health Canada approved pre-market standards and a risk-based post market compliance program;
• Consumers will be able to distinguish between registered and licenced NHPs; and
• Key elements of this new approach would relate to required registration information; record keeping; administration related to product changes and applicable post-market authorities.

The aim this of this initiative is to address administrative burdens that have arisen in the existing process allowing products to come to market faster.

Is improving the current system for NHPs really necessary?
Over the years, the NHP licensing system has become administratively burdensome with extensive reporting and paperwork even for lower risk class I and II products. Current new or innovative product applications can currently take more over 12 months. The issue identification behind this proposal suggests that the government views administrative burdens related to attestations as a regulatory concern over that of an operational concern.

What type of consultation has happened around the initiative to date?
While discussions around about NHP regulations have been ongoing for some time with key stakeholder groups such as the Canadian Health Food Association, a formal proposal has not been made public. A letter to stakeholders was published on February 2, 2026 related to NHPs (as well as non-prescription drugs and biocides) and earlier this year a Stakeholder Feeback Form on Natural Health Products was shared with certain groups. It is not clear what broader consultations might take place with interested groups such as: health charities (charitable patient groups), health insurance providers, pharmacy/retail, health professional groups, programs at all levels of government that fund/promote NHPs, foreign industry associations/government, research organizations, and other bodies interested in trade.

Will all NHPs keep their NPN numbers?
While no final decision has been made, Health Canada maintains the position that consumers must be able to distinguish between “registered products” and licenced NHPs. While registered products are those for which the government of Canada has received and reviewed the most information and, therefore, has the greatest confidence through approved pre-market standards, it is unclear how this approach will improve consumer confidence. Further, it is unclear how communications to the public will capture the difference between registered and licenced products, perhaps registered products would be identified through a new registration number format rather than the current Natural Products Number (NPN).

How will this affect other parts of the regulations such as site licencing?
Until a formal proposal is published, it is difficult to be specific but since components of the NHP regulations are highly integrated, it can be expected that there will be an impact on site licensing.

Will the current NHP regulations need to be amended, or can this be managed through operational changes?
Health Canada has made a commitment to amend the NHP Regulations where necessary. The extent of these amendments will depend on the final approach with the hope that whenever possible amendments can be made through operational changes and/or through a process called incorporation by reference.1

When can we expect a final proposal?
No firm date has been given but initial timelines suggest potential consultations with the general public could begin as soon as autumn 2026.

Where can I find out more about this initiative?
More information can be found on the:
Health Canada website:
https://www.canada.ca/en/health-canada/services/drugs-health-products/natural-non-prescription.html
CHFA website:
https://chfa.ca/news-post/red-tape-reduction-is-an-opportunity-to-get-regulation-right/

Final Thoughts?
There are two things to note about the current initiative. First, a new operational approach is desperately needed as the current system is too complicated, document heavy and overly analytical especially for low-risk products. Second, a new approach is far from being finalised with so many wheels in motion.

Additional points to consider, as the development of the initiative proceeds, include:
• If Health Canada achieves red tape reduction by simply moving unnecessary work and record keeping from the department to industry, this will not be a success.
• Why do consumers need to be able to distinguish between “registered” and “licenced” NHPs? Though applications will not be reviewed by Health Canada, “registered” NHPs will fall within a regulatory framework dependent on risk. If the only reason for the distinguishing between these two types of NHPs is pre-market review, then Health Canada must provide robust and independent evidence as to why this is necessary. If a new type of identification is introduced, it would mean that NHPs could be identified through a “registration” number or an NPN or, for homeopathic medicines, a DIN-HM. This would not make things simpler, nor would it reduce red tape.
• How this red tape reduction initiative is developed is as important as the final product. A key element of this Government of Canada initiative is “improving stakeholder experience and service delivery”. This can only be achieved by engaging the wider community not only to gain different perspectives and opinions but also to take full advantage of the expertise that exists outside of Health Canada.

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About the author:
Michael Smith trained as a pharmacist and as a naturopathic doctor. He is recognized internationally as an expert in natural health products and complementary & alternative medicine. For more than 10 years, he worked in senior regulatory positions at the then Natural Health Products Directorate, Health Canada, and the Therapeutic Goods Administration in Australia. In addition to his international work as a consultant, he is an Adjunct Professor at the National Center for Natural Products Research at the University of Mississippi, USA and an Adjunct Associate Professor at the National Centre for Naturopathic Medicine at Southern Cross University, Australia. Michael is a member of ISURA’s Scientific Advisory Committee.

1. Incorporation by reference (IBR) at Health Canada is a legal drafting technique that makes external documents—such as lists, standards, or guidelines—part of a regulation without publishing them in the Canada Gazette. These incorporated documents are legally binding and allow regulations to remain current and adaptable. https://www.canada.ca/en/health-canada/corporate/about-health-canada/legislation-guidelines/acts-regulations/incorporation-reference-policy.html

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