CA was very pleased to host a critical meeting with Canada’s Health Minister, the Hon. Jean-Yves Duclos at our Mississauga office this past Tuesday. The Ministerial Roundtable meeting was organized in conjunction with the Minister’s media conference in Toronto on the passage of the cosmetic animal testing ban amendments to the Food & Drugs Act.
Joining Minister Duclos in the meeting were Assistant Deputy Minister Matt Jones along with local Liberal M.P.’s Leah Taylor Roy (Aurora-Oak Ridges-Richmond Hill), Majid Jowhari (Richmond Hill), Rechie Valdez (Mississauga-Streetsville), and Iquwinder Gaheer (Mississauga-Malton).
The Minister and MP’s were welcomed by CA Board Chair Gulnara Gabidullina (Procter & Gamble) who noted that this was the first ever visit of a sitting Health Minister to the CA’s offices.
The Minister had requested an opportunity to meet with CA and several of our member companies to discuss our request for “government issued GMP certificates for exports to China”. A copy of CA’s letter accepting the invitation and outlining several other issues which we wanted to discuss can be found HERE.
These “government issued” GMP certificates are required by China to meet their exemption for animal testing on imported cosmetics. Canadian-based cosmetic manufacturing facilities annually export over $350 million worth of product to China and are currently relying on temporary GMP certificates issued by Quebec and Ontario to avoid this unnecessary animal testing in China. Without Health Canada finding a way to issue these certificates – which are outside of Health Canada’s traditional mandate – these exports and the jobs associated with are at risk of being lost to the Canadian economy.
This point was firmly made by representatives of Cosmetica, Galderma, Estee Lauder, Crystal Claire, and L’Oreal who were able to participate in the meeting and who represent a significant portion of Canadian cosmetic exports to China.
CA has been actively pursuing this issue with Health Canada for the past two years including submitting a formal proposal for a voluntary program in August 2021. With a new Minister and the passage of COVID, CA used this opportunity to get the attention of the Minister on this issue. We are pleased that Minister Duclos committed to the immediate creation of a working group between industry and his officials to work out a solution, including tasking ADM Matt Jones with creating the group and managing the issue going forward including providing him with regular updates. The Minister also expects to touch base with CA on this and other issues when we are both expected to be at the World Congress on animal testing alternatives this coming August in Niagara Falls. This, of course, provides some time frame for the working group.
In addition to the China GMP issue, CA used the opportunity to raise our industry’s concerns with three specific matters related to the long-awaited Self-Care Framework modernization. These included:
- Health Canada’s recent proposal for cost recovery for NHP’s which we and other stakeholder view as “putting the cart before the horse” as it is based on the current outdated and unnecessarily costly regulatory framework. Consequently, we urged the Minister to have his Department reassess this proposal and undertake cost recovery in conjunction with the completion of the SCF with its more efficient (and less costly) approach and its’ full range of self-care products available to carry the costs;
- Just getting on with the completion of the SCF which we have been working at for a long time and without which we are losing out on innovation, new products, and a world leading regulatory structure. This point was strongly made by CA Vice-Chair Francois Roberge of L’Oreal; and
- It is time to consolidate the administration of cosmetics with the administration of the other self-care products currently housed at NNHPD. As we noted, it makes no sense to have toothpastes, shampoos, and even lipsticks regulated by two different directorates, in two different branches of Health Canada, and with two different Assistant Deputy Ministers being responsible. This has led to many duplicitous activities and also has made it difficult to advance the China GMP certificate issues as it involves two branches and two ADM’s within Health Canada.
The Minister welcomed this information and support for the SCF and undertook to discuss these concerns with his senior officials. CA was please that we had the opportunity to provide this perspective to the Minister in person as it may not have been presented to him in this fashion by his Department.
The final issue which we raised was the “duplicitous” regulation of cosmetics and other finished consumer and consumer health products by Environment Canada. CA Board Member and Groupe Marcel VP Luc Simard particularly made the point that industry wants to be compliant with health and environmental regulations, but that the best way to do that is with a single window regulatory compliance and enforcement approach under one department which is experienced and knowledgeable about the industry and products being regulated. CA also shared the relevant CUSMA provisions and indicated that trade complaints may be coming if this is not resolved.
The Minster appreciated the information we provided and asked that CA follow-up with a joint letter to both him and the Environment Minister to facilitate a discussion between the two.
In addition to CA President Darren Praznik and VP Beta Montemayor, CA members who were able to participate included:
- Centura Brands – Myles Robinson, President; Vice-Chair CA Board of Directors
- Cosmetica: Neil Sweeney, VP Corporate Affairs; Randy Auld, CEO; Alessandro Mendes, VP of R&D
- Crystal Claire – Marlene Oilgisser
- Estee Lauder – Melissa D’Souza, Global Regulatory Affairs Senior Scientist
- Galderma – Jaclyn Shipp, Regulatory Affairs Manager
- Group Marcell/Lise Watier – Luc Simard, Vice President Operations
- Kenvue (J&J) – Hilary Orr, Director Regulatory Affairs
- L’Oreal – Francois Roberge, VP Scientific & Regulatory Affairs; Vice-Chair CA Board of Directors
- Procter & Gamble – Gulnara Gabidullina, Director Global Product Stewardship; CA Board Chair
- Unilever – Sarah Papadopoulos, Head of Quality Assurance
