Since 2022, as a result of the 2021 CESD audit of NNHPD (https://www.oag-bvg.gc.ca/internet/English/parl_cesd_202104_02_e_43806.html), which noted that NNHPD should have a better understanding of the companies operating and products currently in the Canadian market, NNHPD has been operating a web form to track the market status of licensed NHPs.
Notably, this was always positioned as voluntary. The Market Authorization Web Form (found here: https://forms-formulaires.alpha.canada.ca/en/id/167) continues to describe market status notifications as optional, allowing licence holders to inform NNHPD when a product becomes available for sale in Canada. However, recent procedural changes indicate that market status reporting is becoming increasingly embedded in NNHPD’s licensing framework.
On March 5, 2025, NNHPD introduced the Workload Management Form to support application prioritization. Applicants could attest that their product would be sold or manufactured in Canada within six months of licensing, and their product would be “Prioritized” by NNHPD. Participation/attestation was optional, but those who attested had to commit to update their market status accordingly.
As of December 15, 2025, NNHPD eliminated the standalone workload management forms and fully integrated Canadian market workload management attestation questions directly into the Product Licence Application Form and the Notification and Amendment Form. Applicants must now attest that their product will be sold and/or manufactured in Canada within 12 months of receiving authorization. Importantly, if an applicant does not answer “Yes” to at least one of these questions, the system will not allow the application to be finalized, and the application will not be assessed.
Additional obligations tied to these questions are outlined not in the application questions themselves, nor in the final attestation, but within an informational button linked to these questions. The text states:
To proceed, applicants must select “Yes” in response to at least one of the attestation questions below. By selecting “Yes,” applicants confirm that:
- they will sell and/or manufacture their product in Canada within 12 months of receiving a product authorization.
- they will notify NNHPD once the product is available for sale in Canada.
- they will comply with Section 22 of the Natural Health Products Regulations (NHPR) by providing valid site information.
This distinction matters. An applicant who completes the form without opening the information button would not see that they are committing to notifying NNHPD of market status.
While Section 22 compliance is a clear regulatory requirement, notification of market availability through the NHP Market Notification Web Form is not explicitly required under the Natural Health Products Regulations nor the Food and Drugs Act, and remains described as voluntary on the web form itself.
At this time, NNHPD has not published guidance on how these commitments will be monitored or enforced, nor what the consequences may be if a market status update is not submitted. It is also unclear whether non-compliance could affect future applications, amendments, or compliance activities.
What is clear is that market status updates are seemingly no longer an optional administrative task. By tying application acceptance to an attestation of intended market activity, NNHPD has effectively elevated the importance of accurate and timely market status reporting, even in the absence of formal regulatory amendments.
If you need assistance submitting or updating a market status notification, Dell Tech Laboratories can help guide you through the process and ensure your information is aligned with NNHPD expectations.
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.
