Health Canada has provided a framework for acceptable means of advertising for natural health products (NHP’s). “Guidelines for Consumer Advertising of Health Products” is a document that provides guidance for consumer-directed advertising for non-prescription drugs, medical devices, vaccines, and NHP’s to ensure that messages are compliant with Health Canada’s policies. If you’re a marketing specialist or agency looking for advice on what is acceptable and not acceptable for marketing NHP’s, we’ve summarized the do’s and don’ts to help you ensure compliance.
Product Authorization
DO:
- Paraphrase the claims authorized on the Terms of Market Authorization (TMA) (the product licence as issued by Health Canada – for NHPs, this is called an NPN)
- Use general statements for “beauty shots” that apply to all of the products
DON’T:
- Greatly exaggerate claims that are authorized on the Terms of Market Authorization
- Market an NHP that misleads consumers into believing that it is a replacement for food or cosmetics
Product Performance
DO:
- Advertise products according to the Terms of Market Authorization
- Make it clear that products are self-limiting- a consumer will not suffer if they do not use the product
- Guarantee non-therapeutic effects and satisfaction
DON’T:
- Use exaggerated hyperbolic phrases such as “amazing” or “powerful”
- Advertise products as long-lasting if they only provide temporary relief
- Guarantee therapeutic effects- all consumers are different and some products may not work for some people
Composition
DO:
- Use terms such as “all-natural” only if all ingredients (both medicinal and non-medicinal) meet the definition of natural- processed but still has the same chemical identity as the ingredient found in nature
- Use absence of ingredient claims such as “caffeine/sugar-free”
DON’T:
- Use the phrase “natural action” as all NHP’s alter the body’s function
- Use phrases such as “drug-free” because an NHP is a drug
- Suggest that “natural” products are superior
- Make non-GMO claims if all forms of the ingredient in other products are non-GMO
Comparison
DO:
- Compare the therapeutic effects of products of the same type (NHP vs NHP)
- Compare between: better performance, equivalent performance, and parity (superiority in a given parameter)
DON’T:
- Make these claims without written attestation that support the statements- you must prove the claims you are making to ensure that information is not falsified
Representations of Opinion and Authorization
DO:
- Use statements such as “authorized for sale by Health Canada”
DON’T:
- Make statements such as “approved/endorsed by Health Canada”
Safety/Risk/Side Effects
DO:
- Let consumers be aware of any safety risks with the product
- Provide directions for use such as “read and follow the label”
- Provide risk statements: for videos, audio, and text advertisements the risk statements must be on the screen for an acceptable duration and have clear audio (if applicable), good contrast against the background, legible font and size
DON’T:
- Make statements such as “side effect free” or “100% safe”- all NHP’s may cause some side effects and you cannot mislead the consumer into thinking otherwise
It’s important to advertise Natural Health Products truthfully to consumers by ensuring all claims are consistent with the Terms of Market Authorization (TMA) provided by Health Canada. dicentra offers a full range of services to assist with the marketing of NHP’s. Contact us to find out more or if you require assistance marketing your products!
