The primary goal of health regulation should be to advance
and protect the best interests and health freedoms of
Regulation should seek not to unnecessarily limit consumer
choice but rather to ensure safety through appropriate
good manufacturing practices and clear labelling laws.
Product efficacy should only be a secondary goal no more
restrictive than for other industries.
Regulation should only be used where it can be tangibly
shown to further the good of consumers
New Zealand should
set its own standards and control its own industries. It
must not cede control
Regulation should be appropriate to
each industry based on the actual risk profiles of that
industry. Natural health should be regulated through a
stand alone regulator, not as a division of a larger pharmaceutical
or food regulator.
For regulatory purposes evidence should
be defined to include empirical evidence, effects and results,
traditional use and good science.
Traditional and cultural
products, remedies and treatments should be preserved
and access to them protected
It should be illegal to suppress
any product, treatment or device which can be shown to
be safe and have positive results.
Natural Health Products
should be maintained as a health option for consumers and
protected from commercial attacks from competing industries.
The right to make claims for products, treatments and
devices should be protected on the basis that evidence
The right to advertise and educate the public about
health products and services and medical devices in an
appropriate way should be protected.
Innovation must be encouraged
and the regulatory system should be sure to accommodate
innovation in a financially feasible way.
Health professionals should
be obliged to advise patients of all health choices including
Regulation should be designed so as
to enable low volume products and devices to still be marketed
in a financially viable way.
Naturally occurring ingredients
should only be controlled by way of prohibited or controlled
lists (black list approach - innocent until proven guilty)
and not by a pre approved ingredient list (white list
approach - guilty until proven innocent)
There should not be maximum levels
of naturally occurring ingredients unless there is clear
evidence of significant risk to a wide section of society
without such limits.
Penalties should be appropriate to
the offence and relative to all other non health industries.
penalty imposed should be subject to review by a genuinely
independent authority and in a manner affordable to small
and medium sized enterprises.