Cost-Recovery on Pause for Natural Health Products 

On November 18, 2025, Health Canada released an announcement to stakeholders of their decision to temporarily pause its proposed cost-recovery plan for Natural Health Products (NHPs). 

 

Background: What Was the Cost-Recovery Proposal? 

Health Canada’s cost-recovery proposal, first published in 2023, sought to introduce fees for: 

  • Pre-market evaluation 
  • Site licensing 
  • Annual right-to-sell fees for NPN/DIN-HM products 

These fees were intended to align NHP oversight with other regulated product classes, reduce reliance on taxpayer funding, and strengthen compliance activities. A revised proposal in 2024 included a stepped 7-year phase-in and lowered fee ratios after extensive stakeholder feedback. 

Before the pause, Health Canada had targeted December 1, 2025 for implementation. 

 

The Pause: What Happened and Why 

The government recently launched a Red Tape Review initiative, calling on all departments and agencies to review their regulations, including how they are being administered, and to develop reports detailing their progress.  

On September 8, 2025, Health Canada and the Public Health Agency of Canada published their report on red tape reduction. Below is an overview of the main actions Health Canada is committed to taking as outlined in the report: 

  1. Simplify the registration pathway for certain NHPs and reduce pre-market requirements where post-market surveillance is more appropriate. 
  2. The introduction of flexible risk-based vigilance requirements 
  3. Amend NHP labelling requirements to allow for more flexibilities 

To be clear, Health Canada has not officially cancelled the cost-recovery initiative but confirmed cost recovery for NHPs will not occur on December 1, 2025. 

 

Implications of the Pause: What Comes Next 

While Health Canada remains focused on advancing the policy and regulatory changes set out in the Red Tape Review report, companies avoid significant new regulatory fees on product and site licence submissions and activities. Stakeholders also have a renewed opportunity to engage Health Canada before the fee model is revisited. 

Overall, stakeholders should expect future engagement from Health Canada through new consultations, Canada Gazette notices, or regulatory impact statements. 

 

Contact Dell Tech today for assistance with NHP licence applications, quality assurance, and more.   


DELL TECH HAS PROVIDED PROFESSIONAL, CONFIDENTIAL CONSULTING SERVICES TO THE SPECIALTY CHEMICAL INDUSTRY IN CANADA, THE USA, EUROPE AND ASIA FOR THE LAST 40 YEARS.

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