Natural Health Products (NHPs) are naturally occurring substances that maintain, promote, or restore good health.1 To receive Health Canada approval, an NHP must carry at least one health claim and that health claim must have a health context. For example, “Source of antioxidants for the maintenance of good health.” In addition to the recommended use or purpose statement(s), there are several parameters that form part of an NHP’s Product Licence or Terms of Market Authorization (TMA), including product classification, product representation, composition / ingredients, directions for use, duration of use, risk information, allergen source disclosure, storage conditions, etc.2 Marketing claims can be made around any of these aspects, and while they do not typically appear in the Product Licence Application (PLA) since they lack the required health context, they need to be consistent with the product’s TMA. Product performance, content, comparisons, representations of opinion and authorization, and side effect claims may also be considered marketing language.3 Some examples of acceptable advertising claims are provided in the Table below.
Table 1. Examples of Acceptable Advertising Claims per Guiding Principle3*
| Guiding Principles | Examples of Acceptable Advertising Claims | |
|
1 Product Authorization
|
Authorized Indication / Use: | |
| Helps relieve symptoms associated with menopause. | ||
|
Acceptable Claim: |
||
|
Struggling with menopause? Help relieve your symptoms with Product X. |
||
|
2 Product Performance
|
Authorized Indication / Use: | |
| Helps to reduce joint pain. Use for a minimum of 2 months to see beneficial effects. | ||
|
Acceptable Claim: |
||
|
Product X Glucosamine reduces joint pain when used for at least 2 months. |
||
|
3 Composition: Ingredients / Content
|
Medicinal Ingredient Quantity and Source Material: | |
| 500 mg Echinacea from aerial part(s), root(s) | ||
| Acceptable Claim: | ||
| Naturally sourced Echinacea | ||
|
4 Comparisons A therapeutic comparative claim compares a therapeutic attribute of an NHP to another regarding comparability or superiority, consistent with the respective TMA.
|
Acceptable Claim: | |
| Clinically proven to relieve headaches 32 minutes faster than Analgesic Y. | ||
|
5 Representations of Opinion and Authorization Third-party certifications are acceptable, provided they are consistent with the product’s TMA.
|
Authorized Indication/Use: | |
|
Prebiotic / Source of prebiotics.4 Helps stimulate the growth of healthy bacteria such as Bifidobacteria.4 |
||
|
Acceptable Claim: |
||
|
NutraStrong™ Prebiotic Verified |
||
|
6 Safety / Risk / Side Effects All NHPs have some level of risk associated with them, so implying that a product is safe, side effect free, or has no known side effects, would be unacceptable.
|
Recommend pivoting to another product attribute like “gluten-free” if gluten is present as a contaminant and below the tolerable threshold of 20 ppm. Acceptable Claim: |
|
| Gluten free | ||
*Adapted from Ad Standards3
SGS Nutrasource’s NHP & Pharmaceutical Regulatory Sciences department is well versed in copy reviews, including determining the acceptability of advertising or marketing claims. The experts at SGS Nutrasource will not only review all mandated and voluntary statements, but will suggest alternative, compliant wording, if/where applicable, providing a robust and tailored service offering. Contact us to learn more.
References:
- Health Canada. About Natural Health Products, [Online] Available from: https://www.canada.ca/en/health-canada/services/drugs-health-products/natural-non-prescription/regulation/about-products.html [Accessed 15 Apr 2024].
- Health Canada. Labelling Requirements Checklist, [Online] Available from: https://www.canada.ca/en/health-canada/services/drugs-health-products/natural-non-prescription/legislation-guidelines/guidance-documents/labelling-requirements-checklist.html [Accessed 15 Apr 2024].
- Ad Standards. Guidelines for Consumer Advertising of Health Products, [Online] Available from: https://adstandards.ca/wp-content/uploads/2020/02/Consumer-Advertising-Guidelines-for-Marketed-Health-Products-2020.pdf [Accessed 24 Apr 2024].
- Health Canada. Licensed Natural Health Products Database (LNHPD), 2024. [Online] Available from: https://www.canada.ca/en/health-canada/services/drugs-health-products/natural-non-prescription/applications-submissions/product-licensing/licensed-natural-health-products-database.html [Accessed 24 Apr 2024].
