Ontario Herbalists Association, Etobicoke, ON (2026)

08/26/2026

Facilitated by medical herbalist Meru Parmar, this class is part of a popular series of health and wellness programming through the Burlington Public Library, in partnership with the Ontario Herbalist Association and Medicinale Botanic.

This session introduces the history of herbal medicine, its holistic approach to well-being, and medicinal herbs you may already have in your own pantry.

Enjoy a guided, sensory 'Goethean method' tea-tasting experience that encourages mindfulness and reflection. As you savour your tea, take time to draw or write about what you notice, feel, and learn.

Wednesday September 26, 2026
7 PM - 9 PM
Central Library, Burlington ON

Registration is required - limited spots available!

Click the link for more info and to register:
https://attend.bpl.on.ca/event/16994269

07/11/2026

Health Canada has proposed updates to its Natural Health Product Compounding and Raw Materials Policies that have the potential to influence access to individualized herbal medicine, the diversity of our materia medica, and the day-to-day realities of practitioners, clients, and small Canadian businesses. Until July 12, 2026, Health Canada, specifically the Natural and Non-prescription Health Products Directorate (NNHPD), is taking feedback on the proposed changes.
The British Columbia Herbalists Association (BCHA) has been doing excellent work on this for a long time and we are grateful they have compiled an extensive advocacy toolkit. This includes a step-by-step guide to navigating the Natural Health Product consultation, submitting effective feedback, and making your voice heard.
NHP Policy Consultation Toolkit: https://tr/ee/sg8Q24NK4S
The consultation closes July 12, 2026.

After July 12, you still have the opportunity to voice your concerns with your local Member of Parliament. You can CC your MP on your NNHPD email today or, at a later date, forward the same personalized letter to your Member of Parliament, the Minister of Health, the Director General of the NNHPD, and the federal Health Critics (from the various major political parties).

07/10/2026

For clarity sake, this informed letter about the compounding policy is exceptional if you are struggling to understand the complexity of it all. Please if you need one. Remember July 12 is the last day.

Response to Health Canada's Consultation: Updates to the NHP Compounding and Raw Materials Policies
Thank you for the opportunity to provide comments on Health Canada's proposed updates to the Natural Health Product (NHP) Compounding Policy and Raw Materials Policy.
I support Health Canada's commitment to protecting public health, improving regulatory clarity, and ensuring that broad commercial manufacturing is not inappropriately conducted under the guise of compounding.
At the same time, because these proposed policies have the potential to significantly influence professional practice, compliance expectations, and business operations across Canada's natural health products sector, I believe it is important that both the consultation process and the final policies reflect the principles of transparency, proportionality, and evidence-based decision-making.
These principles are consistent with the Government of Canada's broader approach to regulatory and policy development. The Cabinet Directive on Regulation emphasizes that government interventions should be evidence-based, proportionate to risk, transparent, and developed through meaningful engagement with affected stakeholders, while also recognizing the importance of selecting the appropriate instrument to achieve the desired policy objective.
This distinction is particularly relevant where guidance or policy documents may have significant practical effects despite not creating new legal obligations.
1. Consultation Process and Policy Development
Proposed Policies Should Clearly Reflect Their Status as Proposals
Health Canada's consultation webpage clearly states that stakeholder feedback is being sought on proposed updates to the NHP Compounding Policy and Raw Materials Policy. However, the accompanying policy documents are drafted in the style of finalized guidance rather than proposed policy.
Much of the language is definitive, describing what Health Canada considers to constitute compounding, manufacturing, or the regulatory status of raw materials, with relatively little indication that these interpretations remain open to revision through consultation.
As a result, the documents give the impression that the substantive policy positions have already been established and that consultation is focused primarily on implementation rather than on the proposed interpretations themselves.
Meaningful consultation is strengthened when stakeholders can easily distinguish between existing policy, proposed policy, and areas where Health Canada is actively seeking input.
Clearly identifying proposed interpretations, highlighting substantive changes from previous guidance, and indicating where stakeholder feedback may influence the final policy would better reflect the stated purpose of the consultation and encourage more meaningful participation.
This approach would also align with the Government of Canada's principles for policy development, which emphasize early engagement, transparency, and consideration of stakeholder input throughout the development of initiatives.
Policies Are Not Regulations
These documents are policies, not regulations.
Policies play an important role in explaining how Health Canada intends to interpret and administer existing legislation, but they do not themselves create new legal obligations.
Nevertheless, policy documents can have significant practical effects because they frequently influence compliance decisions, inspection practices, enforcement expectations, and operational decisions.
For many practitioners, suppliers, manufacturers, and small businesses, published policy documents become the practical benchmark against which activities are assessed.
When policy documents are drafted using language that appears definitive and authoritative, they can influence behaviour in much the same way as regulation, despite not having the force of law. This places an important responsibility on Health Canada to ensure that proposed policy interpretations are clearly identified as proposals, supported by transparent evidence and rationale, and remain genuinely open to revision through consultation.
The Need for Clear Policy Rationale
The consultation would also be strengthened by providing a clearer explanation of the rationale underlying significant policy changes.
While the proposed policies identify activities that Health Canada considers to constitute manufacturing rather than compounding, and similarly propose revised interpretations regarding raw materials, they basically emphasize the conclusion more than the analytical framework supporting it.
For significant policy changes, it would assist stakeholders if Health Canada explained:
• the specific regulatory or public health concern being addressed
• the evidence demonstrating that the concern exists
• why the proposed interpretation is considered the most appropriate and proportionate response
• why alternative approaches were not adopted
Providing this context would enable stakeholders to offer more informed feedback, improve transparency, and reinforce confidence that the final policies are grounded in evidence, proportionality, and sound regulatory governance.
2. Principles of Proportionate and Risk-Based Regulation
The distinction between commercial manufacturing and individualized compounding should remain grounded in regulatory risk.
Commercial production intended for broad distribution presents different risks from patient-specific preparations produced following an individualized professional assessment. These activities warrant different approaches.
A proportionate framework allows Health Canada to focus oversight where public health risks are greatest while preserving access to individualized care provided by practitioners acting within their scope of practice.
This approach is consistent with the regulatory principles applied in other comparable regulatory systems. Comparable jurisdictions recognize that commercial manufacturing and patient-specific preparation serve different purposes and may appropriately be subject to different oversight mechanisms.
For example, the United States and Australia distinguish between commercial manufacturing of natural health products or complementary medicines and individualized preparations made for identified patients. While the specific legislative frameworks differ, both systems recognize that patient-specific preparations should not be treated as manufactured commercial products solely because they involve established formulations or similar preparation methods.
Similarly, European jurisdictions generally maintain a distinction between commercially authorized herbal medicinal products and extemporaneous preparations made for individual patients under professional practice frameworks.
These examples demonstrate that maintaining a clear distinction between commercial production and legitimate individualized care is compatible with strong public health oversight. The objective should not be to minimize oversight, but rather to ensure that regulatory requirements are appropriately matched to the nature and risk profile of the activity being regulated.
3. Proposed Compounding Policy
Recognize the Nature of Individualized Practice
The proposed policy appropriately recognizes that patient-specific compounding is distinct from commercial manufacturing. However, additional clarification would help ensure that individualized clinical practice is not inadvertently captured within definitions intended to address commercial production.
Many practitioners (such as naturopathic practitioners, Traditional Chinese Medicine practitioners, clinical herbalists, pharmacists, and others who prepare individualized natural health products) develop formulations based on an individualized assessment of each patient's unique clinical presentation.
Individualized care frequently involves adapting established formulations to meet a patient's specific needs. Modifications may include changes to ingredient selection, ingredient ratios, dosage, or the removal or substitution of ingredients because of allergies, contraindications, sensitivities, interactions, patient preferences, or evolving clinical circumstances.
The repeated application of recognized clinical formulation principles should not, by itself, be interpreted as evidence of manufacturing.
A practitioner may appropriately prescribe variations of a common therapeutic approach while still preparing genuinely individualized formulations for specifically identified patients. Clarifying this principle is important to reduce uncertainty while supporting consistent interpretation.
Avoid Overly Rigid Distinctions That Do Not Reflect Clinical Practice
Individualized healthcare does not always fit neatly into binary categories.
Many systems of healthcare (such as naturopathic medicine, Traditional Chinese Medicine, Western herbal medicine, Ayurveda, and integrative healthcare) are based on adapting recognized therapeutic principles to the individual patient rather than creating an entirely novel formulation for every case.
Policies intended to distinguish compounding from manufacturing should therefore avoid overly rigid criteria that may not accurately reflect individualized clinical practice.
The fact that practitioners may draw upon established formulation principles, traditional formula families, or evidence-informed therapeutic approaches should not, in itself, be interpreted as evidence of commercial manufacturing.
Maintaining flexibility within a risk-based framework would better support patient-centred care.
4. Proposed Raw Materials Policy
The proposed Raw Materials Policy raises separate but equally important considerations.
Raw materials used in the preparation of individualized natural health products (such as botanical ingredients, extracts, homeopathic substances, and other natural health product ingredients) are essential inputs used by practitioners and compounders to prepare patient-specific formulations.
Regulatory approaches affecting access to these materials should therefore be carefully calibrated to the actual risks being addressed.
Any additional controls should be proportionate, evidence-based, and demonstrably necessary to improve public health outcomes.
Restrictions on access to legitimate raw materials should be supported by a clear explanation of the specific risks they are intended to mitigate and evidence that the proposed approach is likely to achieve those objectives.
Consideration should also be given to the cumulative administrative burden that policy changes may impose on practitioners, pharmacies, specialized suppliers, manufacturers of raw materials, and small Canadian businesses, particularly where existing professional standards, quality assurance systems, and supply-chain controls already provide significant safeguards.
The Government of Canada's regulatory approach recognizes the importance of considering regulatory impacts, including administrative burden and the effects on small businesses, when developing regulatory initiatives. The final policy should therefore ensure that any additional requirements are necessary, proportionate, and supported by demonstrated public health benefits.
Health Canada has an opportunity to ensure that the final policy supports both patient safety and continued access to individualized care without creating unnecessary barriers to professional practice, innovation, or the availability of quality raw materials required for legitimate patient-specific compounding.
5. International Regulatory Alignment
Canada's framework should continue to reflect international best practices while remaining appropriate to the Canadian context.
Comparable jurisdictions recognize that commercial manufacturing and patient-specific preparation serve different purposes and warrant different approaches.
The United States and Australia both distinguish between commercial manufacturing of natural health products or complementary medicines and individualized preparations made for identified patients. While the specific legislative frameworks differ, both systems recognize that patient-specific preparations should not be treated as manufactured commercial products solely because they involve established formulations or similar preparation methods.
European jurisdictions similarly distinguish between commercially authorized herbal medicinal products and extemporaneous preparations prepared for individual patients within professional practice frameworks. Although the details vary between jurisdictions, the underlying principle is consistent: products intended for broad commercial distribution and preparations created to meet the needs of identified patient represent different activities with different regulatory considerations.
These examples demonstrate that maintaining a clear distinction between commercial production and individualized care is compatible with strong public health oversight.
Canada's approach should continue to support regulatory objectives while avoiding unnecessary divergence from comparable jurisdictions where such divergence does not provide a clear public health benefit. Maintaining broadly compatible principles supports responsible sourcing of ingredients, innovation, practitioner mobility, and regulatory cooperation, while reducing unnecessary barriers for Canadian practitioners, suppliers, and businesses.
Where Canada's approach differs from comparable jurisdictions, it would be helpful for Health Canada to explain the evidence supporting that divergence, the specific risk being addressed, and the anticipated public health benefits resulting from the different approach.
6. Recommendations
I recommend that Health Canada:
• clearly present the consultation documents as proposed policies under consultation rather than finalized guidance
• distinguish more explicitly between legislative and regulatory requirements and policy interpretations
• identify significant changes from previous guidance and explain the rationale supporting those changes
• provide greater transparency regarding the evidence and policy rationale supporting proposed interpretations
• maintain a clear, risk-based distinction between patient-specific compounding and commercial manufacturing
• clarify that individualized modification of recognized formulations for identified patients remains acceptable compounding
• avoid interpretive approaches that unintentionally capture established individualized healthcare practices
• ensure that policies governing raw materials remain proportionate and evidence-based
• consider the cumulative impacts of additional administrative requirements on practitioners, specialized suppliers, and small Canadian businesses, and
• continue to pursue approaches that support public health while remaining broadly aligned with comparable international jurisdictions where appropriate.
Conclusion
I appreciate Health Canada's commitment to improving regulatory/policy clarity and protecting public health.
This consultation presents an important opportunity, and I want to emphasize the importance of preserving access to (and not over-burdening/over-regulating) individualized care provided by practitioners acting within their scope of practice.
By ensuring that the final policies are transparent, evidence-based, proportionate, and informed by meaningful stakeholder consultation, Health Canada can achieve its public health objectives while supporting innovation, professional practice, and patient access within Canada's natural health products sector.
Thank you for considering these comments.

07/08/2026

This letter is shocking… it’s like having a bucket of ice water thrown in your face. It is written by a lawyer named Shawn Buckley who has been standing up against NHP regulations for years. This is his expertise. This is what he has to say about changes to the compounding law.

07/07/2026

We've seen a bit of confusion about how to participate in the consultation, so here's the simplest way to think about it:

Priority #1: Submit your comments to Health Canada's Natural and Non-prescription Health Products Directorate (NNHPD) before July 12.
This is THE most important step. Use one of our response templates as a starting point, personalize it with your own experience, and submit it through Health Canada's public consultation.

Priority #2: Share far and wide.
Help spread the word by sharing our Consultation Toolkit with colleagues, patients, customers, friends, and family - anyone who cares about preserving access to personalized natural health care and a diversity of NHPs. The more informed voices that participate, the stronger the consultation will be.

Priority #3: Contact your Member of Parliament (MP) & the Minister of Health.
This is an additional advocacy step. We're also creating a separate letter template for this if you'd like to raise your concerns with your elected representative and the Health Minister.

📍You'll find the Summary & response templates in our link in bio on our Instagram

Every respectful, informed, and personalized submission helps decision-makers better understand how these proposed changes may affect Canadians.

07/07/2026

Start…

07/06/2026

Start anywhere … just start

07/06/2026

Wondering where to start?

We've created a **Consultation Toolkit** to help you understand the proposed changes to the Natural Health Product Compounding and Raw Materials Policies—and make it easy to participate if you choose.

You'll find:

📖 A summary of what's happening, why it matters & what you can do to help.

📝 Response templates for:
• Herbal practitioners
• Patients & members of the public
• Small businesses

📤 A direct link to Health Canada's public consultation

Our goal isn't to tell you what to think. It's to help you understand what's being proposed so you can decide what it means for you and share your own perspective.

Everything is available through our IG **link in our bio** or at the following link

NHP Policy Consultation Toolkit
https://tr.ee/sg8Q24NK4S

The consultation closes July 12, 2026

Every informed voice helps shape the conversation.

07/06/2026

Protect your medicine. The rules are changing... unless you grow a medicinal herb garden, it is going to be difficult to get natural sources of medicine from plants to homeopathic remedies. Let your MP know you want choice when it comes to your medicine and write the policy makers. Here is a excellent sample letter from Andrée Noye, a Herbalist in Nova Scotia.

My name is Andrée Noye, MA. I am a Clinical Herbalist in Nova Scotia and the founder of Circé + Medée Herbalists, a community wellness centre in rural Acadie. My work includes individualized herbal care, community herbal education, food literacy, household herbal skills, and access to a broad materia medica.
I am writing in response to Health Canada’s consultation on updates to the Natural Health Product Compounding and Raw Material Policies, which is open until July 12, 2026. I understand that Health Canada is seeking to clarify the distinction between NHP compounding and NHP manufacturing, including when a product or site licence is required.
I want to be very clear from the beginning: I am not opposed to regulation.
I support product safety, accurate plant identification, transparent ingredients, clean preparation, honest labelling, appropriate cautions, good records, accountability, and consequences for harm, adulteration, contamination, fraud, or irresponsible practice.
What I oppose is regulatory design that treats an herbal business with fewer than five employees as if it has the same compliance capacity as a company with 99 employees.
That is not proportionate. It is not realistic. And, from the outside, it creates the troubling perception that small producers and practitioner-herbalists are being regulated out of existence while larger corporations are positioned to absorb the costs, capture the market, and benefit from reduced competition.
Whether or not that is the intention, perception matters. A regulatory model that one-person, two-person, rural, and community-based herbal businesses cannot survive will not be experienced as public protection. It will be experienced as market consolidation.
Health Canada has previously described small business mitigation in relation to NHP cost recovery, but the proposed definition of “small business” includes companies with fewer than 100 employees or between $30,000 and $5 million in annual revenue. A one-person apothecary and a 99-employee company are not meaningfully comparable. They do not have the same legal, administrative, accounting, consulting, infrastructure, or cash-flow capacity. For example, I did not even make $30k in 2025.
A fee reduction for “small business” does not solve the problem if the small business category itself is too broad to distinguish micro-producers from established companies with dozens of employees. Under the current scale, the proposed fee and compliance structure would not mitigate harm to a business like mine. It would effectively put me out of business.
Health Canada’s own materials note that NHP cost recovery has been paused or deferred while program adjustments are considered. I urge Health Canada to use this pause not simply to revise numbers, but to rethink the structure altogether.
There must be a meaningful micro-producer, practitioner-compounding, and community apothecary pathway.
A solo clinical herbalist should not face the same regulatory burden as a high-volume commercial manufacturer. A small rural apothecary should not need corporate-scale compliance infrastructure to continue serving its community. A practitioner preparing individualized herbal medicines within a client relationship should not be treated as though they are manufacturing standardized products for a national market.
Commercially manufactured NHPs and individualized practitioner-compounded herbal medicines are not the same thing.
Commercially manufactured NHPs are standardized products made for the general market. They are produced in advance, labelled for broad consumer use, distributed commercially, and sold to many people with the same formula, dose, and directions.
Individualized practitioner-compounded herbal medicines are different. They are prepared within the practitioner-client relationship in response to a specific person’s health history, constitution, allergies, sensitivities, medications, therapeutic goals, tolerances, cultural context, and changing needs over time.
A practitioner may need to adjust a formula because a client reacts strongly to one herb, cannot tolerate alcohol, needs a tea instead of a tincture, has digestive limitations, has sensory sensitivities, needs a glycerite, needs a topical preparation, or requires a formula that changes over weeks or months.
This flexibility is not a loophole.
It is the point of individualized herbal practice.
Standardized commercial NHPs can be useful, but they cannot meet every person’s needs. Many people seek individualized herbal care precisely because commercial products are too generic, too limited, too expensive, inappropriate for their situation, or unavailable in the form they need.
Access to a robust materia medica is also essential. If raw material access becomes too narrow, too expensive, or administratively burdensome, practitioners will not be able to provide individualized herbal care in a meaningful way. A reduced materia medica does not protect choice. It reduces clinical options.
This issue is not only about products. It is about access to care, continuity of traditional knowledge, rural health options, practitioner autonomy, informed choice, and the ability to respond to people as individuals rather than as generic consumers.
Practitioners like me also help carry some of the day-to-day burden that the current health system cannot fully hold. People come to community herbalists for support with chronic pain management, long-term illness, stress, recovery, food literacy, sleep routines, digestion, and the ordinary maintenance of quality of life. This does not replace medical care. It often fills the space around it.
In rural communities, that space matters. Many people are waiting for appointments, managing chronic symptoms, trying to stretch limited resources, or looking for practical support that is local, individualized, and ongoing. Responsible complementary care can help people stay more resourced between medical visits and better able to participate in their own care.
If small practitioners are priced out of existence, the burden does not disappear. It shifts back onto individuals, families, and an already strained public system.
In my community, herbal medicine is not only a retail product. It is education. It is food literacy. It is seasonal care. It is household knowledge. It is a relationship between practitioner, person, plant, preparation, and place.
I urge Health Canada to ensure that any updated policy or regulatory framework includes:
A clear and durable distinction between individualized practitioner compounding and commercial NHP manufacturing.
A micro-producer or solo-practitioner category that recognizes the difference between a one-person business, a small community apothecary, and a company with dozens of employees.
Fees, licensing requirements, inspection requirements, and administrative obligations scaled to actual size, volume, risk, and distribution.
Fee exemptions or nominal fees for low-volume practitioner-compounded medicines and community-scale preparations.
Protection for access to a broad materia medica and raw herbal materials needed for individualized practice.

Clear recognition that practitioner-compounded herbal medicines prepared within a practitioner-client relationship should not be treated as commercial manufacturing.
Meaningful consultation with clinical herbalists, small NHP makers, traditional medicine practitioners, Indigenous knowledge holders, rural practitioners, and community-based herbalists before final decisions are made.
Transparent evidence that any new fee or licensing burden will improve public safety rather than simply reduce the number of small makers able to operate.
Canadians deserve safe, transparent, and accountable herbal care.
They also deserve access to individualized herbal medicine that is not erased by a regulatory model designed primarily around standardized commercial products.
Regulation should protect people from harm. It should not destroy the livelihood of small practitioners, reduce public choice, narrow access to traditional medicines, or create conditions where only large corporations can afford to remain.
Please ensure that the updated policies protect the continued practice of individualized herbal compounding, preserve access to raw materials, and create a truly proportionate regulatory pathway for micro-producers, solo practitioners, and community herbalists.

07/06/2026

Let's talk about two things herbal practitioners do every single day — and why Health Canada's proposed policies put both of them at risk.

🌿 Dispensing a single herb (a "simple")
When your herbalist fills a bottle with a single-herb extract — say, a high-quality Echinacea tincture at 1:3 potency — calibrated to your specific dose following your consultation, that is a clinical act. It's compounding. The herb has been sourced, identified, prepared, and dispensed within a practitioner-patient relationship.

Health Canada's proposed policy suggests this may not qualify as compounding — which would strip it of the protections compounding practice carries.

Here's what that misses: the Echinacea you find on a health food store shelf is typically a 1:5 or 1:10 extract. Many of our practitioners carry 1:1, 1:2, or 1:3 preparations, grown or wildcrafted with verified plant identification and controlled preparation. These are not the same product. They cannot be substituted.

🌿 Reconstituting a powder with liquid
Health Canada is also proposing that adding liquid to a powder is merely a "direction of use" — not compounding. The CCHA and AHA firmly disagree. The ratio, the diluent, the concentration — these are clinical decisions made for a specific patient. That is compounding, full stop.

We have formally objected to both of these characterizations. More on that in Post 4.

Ontario Herbalists Association

08/26/2026

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