From June 19, 2019 to September 3, 2019, Health Canada held a consultation on the potential market for cannabis health products (CHPs) that would not require practitioner oversight. The purpose of the consultation was to obtain feedback from Canadians and industry on the different kinds of products they would be interested in purchasing, manufacturing or selling if such cannabis health products, for human use or for use in animals, were to be legally available in Canada.
Health Canada published a summary report from the consultation mentioned above. The summary report provides an overview of the comments received from Canadians in regards to CHPs. In total, 1,104 respondents completed the online consultation. Respondents included consumers, industry representatives or other types of interested parties, such as researchers, health and veterinary associations, and government organizations. Health Canada conducted qualitative analysis of the online responses and of the written submissions to identify major themes from the feedback received. Overall, a majority of both consumers (61%) and industry (62%) representatives indicated an interest in both CHPs for human use and for use in animals.
Below are some key points from consumer feedback on the potential market for CHPs:
- Of the 657 consumers who responded to the question “Would you be interested in purchasing a product approved by Health Canada that contains cannabis and is intended to treat minor ailments (e.g., a CHP approved to treat muscle pain)? Why or why not?”, roughly 93% demonstrated a positive level of interest in purchasing or learning more about CHPs to treat minor ailments, 2% were strongly opposed and 5% indicated interest conditional on having further information.
- Consumers who demonstrated a positive level of interest to the question above considered cannabis – particularly cannabidiol (CBD) – as a natural remedy. They noted their preference for greater access to natural alternatives to pharmaceutical drugs and many believed they had experienced various health benefits as well as fewer side effects than they associated with opioids or synthetic drugs. Respondents encouraged Health Canada’s approval of these types of products to ensure safety and quality, while allowing consumer choice and increased access to a wider array of products without practitioner oversight.
- Consumers who were opposed to CHPs either felt there was insufficient evidence to support unsupervised use of cannabis health products or were not interested in purchasing products due to the lack of evidence of the long-term health impacts.
- Overall, consumers have a high interest in seeking out CHPs in a variety of formats and dosages for various purposes. The majority of consumers, approximately 85% (579 participants), described a desire for CHPs to treat issues related to pain and inflammation, such as joint or back pain, arthritis, migraines, or headaches. Mental health issues such as anxiety, depression or stress, were identified as a purpose of interest among 253 consumer respondents. Trouble sleeping was also a common purpose of interest (231 respondents).
- Consumers were also be interested in CHPs to help with the following: gastrointestinal issues (e.g., nausea, indigestion, or issues with appetite), skin conditions (e.g., psoriasis, eczema or skin care), general health, muscle recovery or relaxation, side effects to cancer treatments, behavioural neurological disorders (e.g., autism, attention deficit hyperactivity disorder, multiple sclerosis or Parkinson’s), seizures and other reasons such as concentration, energy, menopause, or other health benefits.
- Most consumers noted current use of cannabis for a range of medical purposes. They felt Canadians would benefit from having access to approved products that are deemed safe by Health Canada and easily accessible. Specifically, about 76% of consumers were aware of sub-populations who would be interested in CHPs and felt anyone experiencing pain, trouble sleeping, or suffering from a chronic or mental health condition would benefit. In particular, seniors, veterans, pets, athletes, or women experiencing menopause were all groups of interest.
- When asked “Do you have preferred product formats for CHPs (e.g., cannabis extracts, topicals, tinctures, or others)?”, consumers responded with comments focusing on safe and easy-to-use product formats, such as topicals or products for oral ingestion. 61% of consumers were interested in products that could be taken orally, particularly as extracts, tinctures, oils, capsules or in sublingual formats. 41% were interested in topicals, such as creams or lotions that would be easy to apply directly for joint pain or sore muscles. 24% either were interested in all formats or did not state a preference and 18% were interested in CHPs edibles or beverages that would be easy to use.
- Additional feedback from consumers affirmed high demand for making CHPs legally available for both human and animal use. While the focus of the consultation was on the potential market for CHPs, consumer participants also provided feedback related to the current rules and requirements for cannabis products under the Cannabis Act.
- Place of sale was a concern among approximately 10% of consumers. In particular, respondents felt that the retail environment for CHPs should be similar to that of over-the-counter drugs or natural health products (NHPs) and should not be restricted to provincially or territorially authorized retailers or federally licensed cannabis sellers. However, about 2% of respondents agreed that measures would need to be in place to prevent direct youth access, such as having CHPs behind the counter at pharmacies.
- About 5% of consumers noted concerns with excessive packaging on current cannabis products and found labelling requirements too restrictive. These participants suggested some level of branding be allowed for CHPs so companies can support consumers in making informed decisions. Other respondents felt the controls put in place by Health Canada were necessary and would ensure quality consistency and safety.
Below are some key points from industry feedback on the potential market for CHPs:
- In total, 253 individuals indicated being a representative of an industry interested in manufacturing or selling CHPs, comprising 23% of all consultation participants. A majority of industry respondents indicated being a member of the NHP (39%) or cannabis industries (25%). Online consultation participants also included representatives of the prescription drug (3%), non-prescription drug (11%), and veterinary health product (12%) industry.
- Approximately 78% of industry respondents expressed an interest in manufacturing or selling CHPs. Of the total industry respondents who expressed an interest in manufacturing or selling CHPs, about 30% were interested in CHPs for human use, 5% specified an interest in CHPs for use in animals and 65% were interested in both.
- The main reason of interest in CHPs by industry representatives is to ensure better consumer choice and access to safe, effective and quality products. They also viewed a potential market for CHPs as an opportunity to expand their business and generate more revenue. Industry comments demonstrated an eagerness to provide clear, consistent and evidence-based information on the potential health benefits and risks of cannabis.
- Approximately 48% of industries represented, including 40% of veterinary industry respondents, indicated a specific interest in CBD-based products. Similar to consumers, formats of preference included oral capsules, topicals (e.g., creams, lotions), extracts (e.g., oils, tinctures) and edible formats. In addition, 24 industry representatives indicated a desire to combine CBD with other cannabis-derived ingredients such as THC, flavonoids, terpenes, and approved NHPs (e.g., vitamins and minerals, essential oils, herbs).
- With respect to health claims of interest, industry representatives from all groups emphasized their preference for providing CHPs for pain relief, inflammation, sleep disorders, and anxiety. Other areas of interest include skin conditions (e.g., eczema, psoriasis) and digestive issues. Approximately 7% of respondents across different industry groups specified interest in bringing CHPs to market for animal use. CBD oils and treats (e.g., soft chews) for pain and anxiety management were of particular interest.
- The proposed evidence standards for CHPs appeared to be both an incentive and a disincentive to bring CHPs into the market. 9 respondents from different industry groups highlighted the need for robust scientific evidence. 18 different industry representatives were in favour of less stringent requirements, to avoid discouraging research and innovation.
- Overall, restricting the sale of CHPs to provincially and territorially authorized retailers or federally licensed sellers was identified as a major disincentive for industry respondents. Almost 40% of all types of industry respondents from the online consultations recommended that CHPs be sold in pharmacies, veterinary clinics or health stores. Respondents felt that having a health care professional such as a pharmacist or a veterinarian available to provide advice to consumers would support informed decision-making. About 58% of the written submissions received from the cannabis and the NHP industries also suggested pharmacy distribution of CHPs to ensure safe use of CHPs and help displace the illicit market.
- About 50% of the total written submissions from the cannabis industry and a few written submissions from health product companies indicated the proposed packaging and labelling requirements would present challenges. They expressed a preference for a broader ability to promote and distinguish their products on the market. Respondents proposed that the requirements should be similar to any other NHP or over-the-counter drug to compete with the illicit market.
- 28% of cannabis industry representatives, 34% of NHP and 21% of the VHP company representatives took the opportunity to urge Health Canada to regulate CBD differently from THC. These respondents recommended a different approach for the regulation of CBD, citing both high market demand and their perception that CBD is a safe substance. Respondents suggested establishing two different pathways for CHPs with THC and CHPs with CBD.
Below are some key points from other interested parties on the potential market for CHPs:
- Out of all respondents to the online consultation, 167 (15%) identified themselves as other interested parties.
- 21% of participants indicated being a healthcare professional or association representative.
- 15% identified as a veterinary professional or association representative.
- 9% identified as academics or researchers.
- 5% represented provincial, territorial or municipal government organizations.
- 4% represented non-governmental organizations (NGOs).
- 3% identified as advocacy group representatives.
- 26% of participants specified being a part of “other groups” such as regulatory consultants or legal representatives.
- A number of healthcare and veterinary associations and professionals suggested that discussions regarding CHPs are premature. Many of these respondents expressed significant health and safety concerns about CHPs, while levels of support and perspectives from the other respondents varied.
- Similar to consumers and industry representatives, different types of respondents in this group described more than one purpose of interest. Comments indicated an interest primarily for pain relief, mental health purposes (e.g., anxiety) or as a sleep aid (refer to Figure 7). Of these respondents, 50% of healthcare professionals, 56% of researchers, and 32% of veterinary professionals indicated the most interest in pain relief. Healthcare professionals also demonstrated the greatest interest in mental health purposes (70%).
- Health and safety concerns were a common theme among representatives from all other interested parties. In particular, 72% of the 39 representatives from healthcare associations or health professionals disclosed health and safety concerns. A shared concern among this group was the lack of scientific evidence on the potential negative effects of cannabis, particularly on the risks for women who are pregnant or breastfeeding, those with mental illness, or among youth. Healthcare association representatives highlighted the need for a cautious approach, and recommended having CHPs available only as scientific evidence becomes available to support (or refute) claims.
- About 22% of veterinary professionals and associations who completed the online consultation also expressed health and safety concerns for pets, including the risk of toxicity, interactions with other medications, and side effects. Written submissions from medical professional associations noted public health concerns (e.g., ingestion by young children) with increased availability of CHPs. As a recommended measure, they advised strict packaging and labelling requirements be put in place.
- Due to a lack of valid research and evidence and the need to protect youth, 40% of healthcare professional respondents and 33% of representatives from healthcare associations who completed the online consultation recommended the need for practitioner oversight for CHPs.
Currently, Health Canada is working to establish a Science Advisory Committee for Health Products Containing Cannabis to provide independent scientific and clinical advice to support the Department’s consideration of appropriate safety, efficacy, and quality standards for health products containing cannabis, including the conditions under which these products would be suitable to be used without practitioner oversight (e.g., dose and indication).
The information gathered through this process will lay out the next steps on the development of a potential regulatory pathway for health products containing cannabis that would be available for use without a prescription.
To learn more about the potential market for cannabis health products and read the full summary report of the overall feedback received, click here.
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