Have Your Say in Around 10 Minutes

We’ve made this as easy as possible!

Below are our suggested prompts and key points to help you answer the Ministry of Health’s consultation questions, based on the principles we consider important for natural health products.

Where you are asked to “Please explain your answer”, you don’t need to write lengthy responses. Simply choose one or two of the bullet points below that reflect your views and use them in your answer. You can copy and paste them, put them in your own words, or expand on them if you wish.

The important thing is to have your say!

Feedback closes 11:59 pm on Monday, 2 November (NZ time): https://consult.health.govt.nz/regulatory-policy/natural-health-products/consultation/intro/

Personal Questions

Questions 1-4

Answers to these questions are personal to you.

Purpose and objectives

5. Do you agree that natural health products should have a dedicated regulatory system?

Suggested selection: Disagree

[Choose one or two and expand where you feel necessary:]

• Existing legislation already provides consumer protections.
• Government needs to demonstrate why current laws are inadequate before introducing new regulation.
• Government can address identified risks through targeted amendments to existing laws.
• Avoid unnecessary new bureaucracy, compliance costs and restrictions.
• Preserve consumer choice and affordable access.

6. Do you agree or disagree with the proposed objectives?

Suggested selection: Disagree

[Choose one or two and expand where you feel necessary:]

• Product safety and quality are important but do not justify a new regulatory regime.
• Consumer choice and affordable access should be primary objectives.
• Protect traditional products and established natural health practices.
• Avoid unnecessary costs for small businesses and consumers.
• Require evidence that additional regulation will deliver measurable benefits.

Guiding principles

7. Do you agree or disagree with the proposed principles?

Suggested selection: Neutral

[Choose one or two and expand where you feel necessary:]

• Demonstrate the necessity for additional regulation before introducing it.
• Require the least restrictive effective approach to identified risks.
• Ensure benefits outweigh costs, including impacts on consumer choice.
• Prioritise New Zealand’s interests over unnecessary international harmonisation.
• Resolve conflicts between consumer choice, regulatory efficiency and international standards.

8. Are there any other principles that should be considered?

[Choose one or two and expand where you feel necessary:]

• Presumption of continued access to lawful natural health products.
• Consumer autonomy and freedom of informed choice.
• Protection of traditional remedies and small businesses.
• Transparent evidence, cost-benefit assessments and regulatory accountability.
• Preference for improving existing legislation over creating new regulation.

Scope, ingredients and pre-market requirements

9. Should a future regulatory system include both edible and inedible natural health products that make health-related claims?

Suggested selection: No.

[Choose one or two and expand where you feel necessary:]

• Edible and inedible products have different risk profiles.
• Health-related claims should not automatically trigger additional regulation.
• Existing consumer protection laws already address misleading claims.
• Restrictions should require credible evidence of actual risk.
• Preserve access to traditional and low-risk products.

10. Which approach would work best for identifying permitted ingredients?

Suggested selection: A list of prohibited ingredients

[Choose one or two and expand where you feel necessary:]

• Preserve access unless credible evidence justifies restrictions.
• Avoid approved lists that automatically exclude unassessed ingredients.
• Protect ingredients with established histories of safe traditional use.
• Require transparent evidence and justification for prohibitions.
• Use existing powers to restrict genuinely unsafe ingredients.

11. What level of pre-market oversight is appropriate?

Suggested selection: Another approach

[Choose one or two and expand where you feel necessary:]

• No additional registration or approval without demonstrated necessity.
• Existing product safety and consumer protection laws should be prioritised.
• Avoid costly pre-market requirements for low-risk products.
• Protect small suppliers from disproportionate compliance costs.
• Address identified risks through targeted enforcement and existing legislation.

Health claims

12. How should health claims for natural health products be enabled?

Suggested selection: Rely on general consumer protection laws only

[Choose one or two and expand where you feel necessary:]

• Allow truthful, appropriately substantiated health claims.
• Recognise both scientific evidence and traditional-use evidence.
• Distinguish traditional claims from clinically established claims.
• Use existing laws to address false or misleading claims.
• Avoid unnecessary pre-approval requirements that restrict consumer information.

Manufacturing and labelling

13. What considerations should apply to manufacturing rules for natural health products?

[Choose one or two and expand where you feel necessary:]

• Assess existing manufacturing requirements before introducing new rules.
• Apply standards proportionate to demonstrated product risks.
• Avoid unnecessary pharmaceutical-style manufacturing requirements.
• Protect small producers and traditional practitioners.
• Require evidence that additional standards improve consumer safety.

14. What considerations should apply to rules around labels for natural health products?

[Choose one or two and expand where you feel necessary:]

• Retain existing labelling laws wherever adequate.
• Require clear, accurate information and relevant safety warnings.
• Avoid unnecessary restrictions on truthful product information.
• Minimise relabelling costs for small businesses and importers.
• Justify additional requirements through demonstrated consumer risks.

Exemptions

15. Should any groups or product types be exempt from all or some regulatory requirements?

[Choose one or two and expand where you feel necessary:]

• Establish the need for additional regulation before considering exemptions.
• Exempt or simplify requirements for low-risk products.
• Protect traditional practitioners and longstanding remedies.
• Avoid disproportionate costs for small suppliers and specialist products.
• Preserve access to low-volume and niche natural health products.

Oversight and regulation

16. What considerations should apply in determining the form and functions of a regulator?

[Choose one or two and expand where you feel necessary:]

• Use existing regulatory agencies wherever possible.
• Avoid creating another unnecessary regulatory authority.
• Require transparent decisions and clearly limited statutory powers.
• Provide independent review and appeal mechanisms.
• Demonstrate that additional bureaucracy delivers measurable public benefits.

17. What roles should a regulator have, and how should this be funded?

[Choose one or two and expand where you feel necessary:]

• Prioritise existing agencies and enforcement powers.
• Limit regulatory functions to demonstrated consumer safety needs.
• Avoid unnecessary licensing, registration and approval fees.
• Protect small businesses and consumers from increased costs.
• Require transparent funding, accountability and proportionate enforcement.

Final comments

18. Is there anything else you would like to tell us about the future regulation of natural health products?

[Choose one or two and expand where you feel necessary:]

• Demonstrate why existing legislation is inadequate before introducing new regulation.
• Preserve consumer choice, affordable access and traditional health practices.
• Protect small businesses from unnecessary compliance costs.
• Require credible evidence of risk and comprehensive cost-benefit assessments.
• Publish detailed proposals and undertake meaningful public consultation before introducing legislation.

Publication and privacy

Questions 19-21

These questions concern publication of your submission, personal information and commercial sensitivity. Answer them according to your own preferences.

Remember!

These are suggested responses and points to consider, not answers you must adopt. Select the arguments you agree with, explain them in your own words and include your own experiences wherever possible.

Submissions close at 11:59 pm on Monday, 2 November (NZ time).

Submit online: https://consult.health.govt.nz/regulatory-policy/natural-health-products/