Peterborough and the Kawarthas Chamber of Commerce Vice President, Operations and Government Relations, Joel Wiebe will be attending a conference with Chambers across the country to discuss proposed policy resolutions.
Wiebe will be touching on Improving the Regulatory Environment for Natural Health Products, High Frequency Rail, Supporting International Students Entry to the Canadian Workforce, and Tax Fairness for Healthcare Professionals. Here are some of the following policy resolutions that will be discussed. Improving the Regulatory Environment for Natural Health Products In Canada, oversight of Natural Health Products (NHPs) falls under the Natural Health Products Regulations (NHPR) of the Food and Drugs Act. These regulations came into effect on January 1, 2004, after consultation with stakeholders and the public to determine an appropriate regulatory framework for NHPs. At that time, it was agreed that it was not proper to regulate natural products under the same regulations as chemical drugs or impose the same standards of evidence onto natural health products. In 2017, Health Canada launched a consultation on the regulation of self-care products. In 2021, Health Canada conducted consultations regarding proposed regulations to amend the Natural Health Products Regulations with the purpose of gathering feedback on proposed improvements to natural health product labelling. In addition, it was cited that the proposed amendments were anticipated to decrease the regulatory burden and costs to businesses, as well as introduce greater efficiencies for businesses. Since then, new proposed regulations were introduced creating concerns around the future of Natural Health Products (NHP) in the Canadian Market, from new fees and charges imposed, to the increased regulatory burden and the inequitable treatment of natural health care products. Most recently, in 2023, Health Canada provided information related to the fee proposal with the intention to start charging new fees on April 1, 2025, in addition to increasing the regulations. There is value in making sure products claiming health benefits are safe, but these standards do not take into account the wide variety of NHPs. While some offer alternatives to pharmaceuticals, many are considered supplemental to pharmaceuticals like vitamins, probiotics, and amino acids. Many of these products are not normally healthcare-associated, like natural deodorants, sunscreens, toothpaste, and skin care products. According to the Canadian Health Food Association’s Save Our Supplements campaign, 76% of brands say there is a high/very high chance they will need to pull product from the market as a result of these regulations. One in five companies say they are seriously considering leaving the Canadian market. Additionally, 66% of companies said it would have a negative impact on employment. Dating back to 1998, with the report of the Standing Committee on Health, Natural Health Products: A New Vision, it has been recognized that there is a legislative and regulatory regime required to govern traditional medicines (including, but not limited to, traditional herbal remedies, traditional Chinese, Ayurvedic and Native North American medicines), homeopathic preparations and vitamin and mineral supplements, taking into account the needs of associations, consumers, manufacturers, distributors, growers, importers, exporters, retailers and practitioners. The guiding principle since that time has been to establish a regulatory framework for NHPs that (1) protects the health of consumers (2) respects consumers' access to products and (3) guarantees product safety and quality. With limited implementation timelines, exorbitant fee increases and additional regulatory burdens, the new standards will cause significant issues within the industry and government. The fees, regulations and compliance costs are viewed as unnecessary changes to a system that was deemed to be working after the Natural Health Products Regulation in 2004. Canada already had some of the strictest regulations for NHPs prior to the new regulations. Once fully implemented, it will have the most stringent regulations on NHPs in the world. Many of our trading partners, including the US, Australia, EU, Japan, and China have different classifications based on the product’s composition, claim, and intended use. These factors will determine whether it is a supplement or medicine. As of 2022, Health Canada had licensed over 120,000 NHPs.6 With the increased demand for Natural Health Products and Practices and the increasing regulatory environment, there has been increased awareness regarding the need for legislation that will ensure a better regulatory environment for Natural Health Products and Practices, including calls for a proposed Charter of Health Freedom Act.7 The health and wellness industry recognizes the need for a more balanced regulatory environment and structure, built in consultation with industry, while still achieving the guiding principles of protecting the health of consumers, respecting consumers’ access to products and guaranteeing product safety and quality. Businesses in the health and wellness sector understand the regulations imposed in 2004, citing that they have been the best regulatory regime of NHPs in the world with the expertise and time invested in that process. However, the most recent cost recovery model and amendments to the Food and Drugs Act, as of December 22, 2023,8 will not achieve the desired outcomes without the same due diligence and consultation as previously conducted with industry. Recommendations: That the Government of Canada: 1. Replace the definition of therapeutic product in section 2 of the Food and Drugs Act with the following: therapeutic product means a drug or device or any combination of drugs and devices, but does not include a natural health product within the meaning of the Natural Health Products Regulations. 2. Repeal Section 21.321 of the Food and Drug Act and Subsection 21.8(2) of the Food and Drug Act to reverse the changes imposed by Bill C-47 section 500-504. 3. Eliminate additional fees, until fee levels are re-examined in consultation with industry. 4. Consult with the Natural Health Product industry to come up with a globally competitive strategy to address safety concerns, and the differentiation between medicinal NHPs, supplements, and other consumer products while taking into consideration costs and the regulatory impacts for businesses of all sizes. 5. Implement the Standing Committee on Health’s recommendations from the report: Natural Health Products: A New Vision. 6. Only implement new regulatory changes once backlogs are cleared, operations run efficiently, and policies and procedures are in place to ensure stable operations continue for Natural Health Products. High Frequency Rail The upturn in passenger rail transport is well and truly back on track since the end of the pandemic. More than four million passengers used VIA Rail trains in 2023, representing a 24.7% increase over 2022. Between 2021 and 2022 alone, cumulative ridership increased by 116.2% in the Quebec-Windsor corridor. This enthusiasm for intercity travel on VIA Rail trains is, however, hampered by the fact that VIA Rail owns only 3% of the infrastructure on which its trains run. With 60% of Canada’s population residing along the corridor, the HFR project becomes a strategic issue for Canada in the following respects: • Job creation: the VIA HFR Inc. project is expected to create thousands of jobs over the life of the project. • Economic development: As part of the VIA HFR project, the state-owned company will expand its existing network by more than 1,000 km of track, and expects to see a marked increase in ridership in the Corridor, thanks to reduced travel times, increased punctuality and more departures in certain parts of the Corridor. By connecting more communities with more and more punctual departures, schedules better adapted to business needs and faster journeys, the HFR project will help weave commercial links by simplifying business travel and making it easier to work and rest on board trains. The HFR project will also enable employers in the corridor to expand their labour pool by combining transportation and work. 55 • Tourism: in 2022, tourism accounted for 2.02% of Canadian GDP and 1 in 10 jobs, according to Statistics Canada. Between 2024 and 2030, the Canadian economy is expected to grow by 4.1% annually, while the tourism sector will grow faster, by 5.8% on the same basis. • Nevertheless, growth in the tourism sector is below the global average. Mobility between major urban centres will therefore play a key role in the coming years. The HFR project will make intermodal connections more fluid by increasing the number of transfers between different means of transport, with the aim of attracting more tourists to inland Canada. As such, in 2024, spending on business and leisure travel in Canada will exceed that of 2019. • Optimizing infrastructure: As identified by several chambers of commerce, the creation of a separate passenger rail corridor between Quebec City and Toronto will benefit the freight sector, which will also be able to optimize its own infrastructure and generate more economic activity. Consider, for example, the benefits of further optimizing rail lines to transport coastal products from the Prairies even more efficiently, or consumer goods that travel the distance by rail between British Columbia and Quebec. The HFR project will also free up some of the road traffic on the corridor’s highways, which represents a major congestion issue between cities. • GHG reduction: Thanks to the higher number of frequencies, the punctuality of trains on dedicated tracks and the increased speed of journeys, the train is becoming an alternative to the car. In its 2017 report Stuck in Traffic for 10,000 Years, the Canadian Chamber of Commerce stated that an HFR would cut congestion by 2.4 million cars along the corridor, in addition to reducing highway maintenance costs. The HFR project includes track electrification, so that the newer engines will be ready to run on it. The introduction of an HFR will contribute to Canada’s efforts to meet its new GHG reduction target. • It is worth noting that a number of municipalities have publicly expressed their wish to see the VIA HFR project come to fruition, with the aim of starting up service as soon as possible, including open letters signed by the mayors of Toronto, Peterborough, Ottawa, Montreal, Trois-Rivieres and Quebec City. More than half of all trip segments are not between two major cities on the current route. Recommendations: That the Government of Canada: 1. Urge VIA HFR to proceed with the entire HFR project as quickly as possible. 2. Gives priority to the HFR project and other passenger rail services on dedicated tracks as essential ways to meet our climate objectives. 3. Develop a strategy to extend HFR service beyond the current Toronto-Quebec City project. Supporting International Students Entry to the Canadian Workforce International students have long been integral to the socio-economic fabric of Canada, contributing significantly not only as a skilled workforce but also enriching the cultural landscape of the communities in which they reside. Historically, these students have faced stringent work limitations that conned their off-campus employment to a maximum of 20 hours per week. In response to acute labor shortages across various sectors, the Government of Canada enacted a temporary measure in November 2022, allowing these students to exceed this limit. Initially set to expire in April 2023, the policy was extended to April 2024, recognizing its broad benefits. The policy was not extended and a 24-hour cap on International Students during the school terms was introduced as of May 1, 2024. International students typically pay between 2.9 and 5.3 times more for their education than domestic students . While there are some financial supports for international students, they are not eligible for many of the supports domestic students receive, like student loan programs. Many rely on working in Canada to help pay for their school and living expenses. Unfortunately, those work experiences are limited. International students often turn to the underground economy to increase their hours. This makes them vulnerable to exploitation and abuse. These jobs may pay less than minimum wage and it creates a power imbalance as the students have no legal recourse to demand payment because they are working in violation of their study permit. This progressive policy of extending the number of hours the International Students could work has proven vital for both the students and the Canadian economy, particularly in smaller cities and communities like those in Quinte West. By working more hours per week, international students have not only been able to better support themselves financially but have alleviated staffing shortages, filling critical gaps in the labor market, particularly in sectors like hospitality, retail, personal care and entry level manufacturing, which often struggle to attract local workers. These roles, while crucial, are frequently undervalued and understaffed, yet they form the backbone of our local economy, ensuring the operation of community essentials from restaurants to retail stores. The ability for international students to work additional hours has enhanced the students' educational experience by providing them with real-world work experience in a global setting and increased their contributions to the economy through taxes and consumer spending. More importantly, this policy has allowed them to earn a livable wage, which has reduced their need to rely on limited and overburdened social services. The evidence is clear: international students significantly bolster our workforce, particularly in sectors that struggle to attract domestic employees. Their contribution extends beyond filling labor gaps; they enhance our cultural landscape, stimulate economic activity through their spending, and alleviate pressures on our social services by being financially self-sufficient. Allowing these students to work more hours has proven to be a successful policy, not just as a temporary relief measure but as a potential long-term solution to ongoing labor market challenges. However, the benefits currently realized are at risk now with the new measures that have been introduced. The resulting reduction in work hours to 24 hours per week, will not only reverse the gains we have made but could also push many students into precarious living conditions or compel them to seek work in unregulated environments where they are vulnerable to exploitation. Moreover, the current housing crisis and the rising cost of living exacerbate these risks, making it even more critical to maintain and enhance their ability to work sufficient hours. Now the temporary measure of full-time hours during school terms has expired, there is a critical need to not only reassess its impacts but also to advocate for its extension and enhancement based on empirical evidence and the positive outcomes observed. The Quinte West Chamber of Commerce, representing both the business and civic interests of our community, recognizes the dual benefits of this policy to our local economy and the international students’ welfare and thus proposes a strategic approach to make these changes permanent, ensuring the continued prosperity and inclusivity of our community. By providing additional oversight to protect them as they enter the Canadian workforce during their studies, by strategically guiding them towards in demand careers, and by allowing them to work the number of hours necessary to meet the high cost of living in Canada, there is a greater chance they will have success entering the Canadian workforce after graduation. Therefore, the Quinte West Chamber of Commerce proposes a series of strategic measures designed to solidify and expand the current policy framework. These include making the increase in allowable full time work hours permanent, improving regulatory oversight to protect students in the workplace, and providing targeted support services that address both the immediate and long-term needs of international students. Recommendations: That the Government of Canada: 1. Implement a policy allowing international students to work full-time hours during academic terms. 2. Support financial literacy programs tailored for international students to help them manage their finances effectively, including Canadian banking, savings, fraud prevention and tax systems Tax Fairness for Healthcare Professionals The federal Excise Tax Act provides the Canada Revenue Agency with a number of exemptions to the collection of sales tax. Schedule V, Part II of the Act 1 defines healthcare services and section 7 specifically lays out what individual service practitioners are exempt. The Act lists 13 specific services like chiropodic, physiotherapy, and naturopathic services. There are notable registered professions missing from this list, including registered massage therapists. The registered massage therapy sector met the criteria for harmonized sales tax exemption in 20192 by achieving five provinces regulating the profession. These provinces are Prince Edward Island, Ontario, British Columbia, New Brunswick, and Newfoundland and Labrador. The Canadian Massage Therapist Association has requested exemption from the Ministry of Finance, but no action has yet been taken from the federal government. Psychotherapists have been in the same situation, but the federal government is now in the process of approving a sales tax exemption for this mental health profession. It’s fair for the Government of Canada to set baseline criteria for providing HST exemptions to ensure only those held accountable through regulated professions can be afforded this support. However, it’s also incumbent on the Government of Canada to grant approval in a prompt manner when those criteria have been met. Waiting five years with no indication of any action is unacceptable. Recommendations: That the Government of Canada: 1. Level the playing field for all regulated healthcare professions by providing sales tax exemptions for all providers that meet regulation requirements, including Registered Massage Therapists 2. Begin the sales tax exemption process within one year of complying with regulation criteria Comments are closed.
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