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AHPA's communications to relevant governmental bodies seek clarification, resolution to regulatory cost concerns in Canada and import challenges in Mexico November 11, 2023 On behalf of its members that have commercial interests in Canada and Mexico, the American Herbal Products Association (AHPA) has sent communications on two separate issues impacting the dietary supplement trade with these countries. As geographical neighbors and long-standing trading partners, Canada and Mexico represent significant economic markets for United States-based natural products companies. Regulatory cost concerns in Canada In Canada, a regulatory proposal to establish user fees for the registration, manufacture, and sale of natural health products (NHPs) was introduced by Health Canada. While such a proposal was expected by the industry, significant concerns have been raised about the overall structure of the proposal and the calculation of the associated fees. Health Canada conducted a public consultation on the proposal that concluded in August 2023, and AHPA's International Committee developed and submitted responses to the questions that formed the consultation. AHPA has now also communicated with the U.S. Trade Representative and the U.S. World Trade Organization Technical Barriers to Trade inquiry point. These communications raised concerns about whether the structure of the Health Canada user fee proposal complies with specific provisions of the United States-Mexico-Canada Agreement with respect to the calculation of the proposed user fees and whether the user fees impose an inequitable burden on foreign products. Import challenges in Mexico With Mexico, AHPA member companies have been experiencing challenges in obtaining import permits for dietary supplement products from COFEPRIS (Comisión Federal para la Protección contra Riesgos Sanitarios), the regulatory agency charged with this authority. No changes have been made to the Mexican national regulations, and local supplement associations have been unsuccessful in meeting with COFEPRIS to better understand the issue. In the absence of a functional import permit process, inventories of some dietary supplement products have become critically low, causing supply chain issues for Mexican distributors and retailers. AHPA, along with other U.S. and international supplement associations, has submitted communications to the Mexican Ministry of Health and the Mexican Ambassador to the United States with the objective of gaining an understanding of the issues inhibiting the process of issuing import permits. AHPA respectfully requested that companies with established business in Mexico be promptly informed of any changes to the import permit processes and allowed a reasonable amount of time to take actions such as reformulation or changes to product labeling as may be needed. AHPA appreciates the work of its International Committee in bringing these concerns forward and supporting the development of appropriate responses that represent the interests of AHPA members and the wider industry impacted by these issues.