Fee proposal for drugs and medical devices

Canadian hog producers are committed to the production of safe, high quality pork. Having access to safe and effective veterinary drugs is essential to producers. These products are an important tool in helping producers raise healthy pigs.

The CPC is concerned that the proposed fees for drugs will have a significant negative impact on producer’s ability to access the required animal health products.

In comparison with many of its larger competitors (e.g. United States of America), Canada has a small market for animal health products. It is the Council’s view that Health Canada’s proposed fee increases will result in fewer products being brought forward for approval and may result in some products being withdrawn from sale. In establishing fee structures, the ability of the Canadian market to sustain increased costs must be taken into consideration.

Limiting access to improved animal health products will have negative consequences for the Government of Canada’s commitment to address antimicrobial resistance. Hog producers have been supportive of the pan-Canadian strategy. A key component of the sectors’ response has been to improve its stewardship effort by utilizing alternative products that result in lower usage of existing medically important antimicrobials.

Producers have been funding the research and development of new technologies that will help them to better care for their animals. This is a pillar of the federal government’s Pan-Canadian Framework for Action1 on antimicrobial resistance as well as the Federal Government’s Plant and Animal Health Strategy2. The CPC is concerned that the increased fees will discourage further spending on research if new products cannot be brought to market.

The Council would like to reference the analysis3 conducted by the Canadian Animal Health Institute (CAHI) regarding the impact of the proposed service fees. If implemented, CAHI estimates that the “proposed fees will make justifying a Canadian registration next to impossible”. Consequently, the animal agriculture sector will “lose products currently licensed for the Canadian market and many new products will never seek marketing authorization in this country”.

Ultimately, the fee proposal threatens the competitive position of Canada’s pork sector. Canada is a global leader in pork production and is the third-largest exporter of pork in the world ($3.8 billion in 2016). Pork producers contribute significantly to the Government of Canada’s goal of expanding agriculture and agrifood exports to $75 billion. For Canadians this means not only economic growth, but also access to ready supplies of locally produced, affordable, high-quality protein. As the data from the Canadian Centre for Food Integrity shows, the top two concerns for Canadian consumers are the rising cost of food and keeping healthy food affordable4. Therefore, it is important to ensure changes to the fee schedule would not inadvertently harm the availability of healthy and affordable proteins for Canadians.

Canada’s animal health status is a critical advantage in an extremely competitive global pork market. Should Health Canada’s proposed fees result in fewer drugs and medical devices being available to producers, this advantage could be lost resulting in reduced exports and/or increased imports. Canadian producers must have access to the same health management tools as our competitors.

The Canadian Pork Council is supportive of efforts to maintain and improve animal and human health in Canada.

However, it is the view of the Canadian Pork Council that Health Canada should:

  1. Take into account the importance of having access to safe, effective and competitively priced veterinary drugs in order to produce safe, nutritious, affordable protein for Canadians.
  2. Consider the option of establishing veterinary drug service fees that are reflective of the size of the Canadian market.
  3. Redraft the proposal to ensure Canadian producers are not placed at a competitive disadvantage with international competitors when it comes to accessing safe and effective animal drugs.

1. Tackling Antimicrobial Resistance and Antimicrobial Use: A Pan-Canadian Framework for Action. [Internet] Public Health Agency of Canada, 2017. https://www.canada.ca/en/healthcanada/ services/publications/drugs-health-products/tackling-antimicrobial-resistance-use-pancanadian-framework-action.html
2. A Plant and Animal Health Strategy for Canada. [Internet] Canadian Food Inspection Agency, 2017. http://www.inspection.gc.ca/about-the-cfia/accountability/consultations-andengagement/pahs/draft-for-consultationpurposes/eng/1490390513931/1490390586446?chap=0#c2
3. CAHI submission
4. Canadian Centre for Food Integrity 2017 Public Trust Research. http://www.foodintegrity.ca/wpcontent/ uploads/2017/09/ENG2017Summit-ResearchBook-Final-LR.pdf