Homeopathy & NZ's Therapeutic Products Bill

Homeopathy aka Low Concentration Natural Health Product

The latest folly out of New Zealand is the imminent Therapeutic Products Bill intended to replace the Medicines Act 1981 and the Dietary Supplements Regulations 1985 to provide for the comprehensive, risk-proportionate regulation of therapeutic products, such as medicines, medical devices, natural health products, and active pharmaceutical ingredients.

J R Bruning provides Bill breakdown and critique via Substack Therapeutic Products Bill: Labyrinthine & unaccountable as it exits the starting gate? and courtesy of The Daily Telegraph (New Zealand) THERAPEUTIC PRODUCTS BILL – THE DEVIL IS IN THE DETAIL

Guy Hatchard’s (PhD) darkly humoured Bill commentary is scathingly factual and includes THE NZ GOVERNMENT REACHES FOR TOTAL MEDICAL CONTROL

The Bill underwent its first reading on 14 December 2022 and is currently accepting public submissions until 05 March 2023. New Zealanders are encouraged to make their own submission.

New Zealand based pharmacist & homeopath Barbara Roberts comments on the Bill and it’s potential impact upon herbal medicines.

New Zealand Doctors Speaking Out with Science (NZDSOS) ask ‘what would happen if we could get a million people to say: No, we don’t want Natural Health Products regulated?’ providing an ‘how to’ make a submission.

A petition exists and can be signed to reject the proposal (Bill) to regulate foods and herbs and traditional medicines which is unlawful, irrational, unreasonable and unnecessary and contrary to New Zealanders’ interests.

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Homeopathy will be defined as a Low Concentration Natural Health Product.

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My public submission concerning the Therapeutic Products Bill as follows;

My name is Sarah Penrose, and I hereby state my right of opposition to the Therapeutic Products Bill.

I am particularly opposed to the inclusion of Natural Health Products, concerned the legal standing of which appears to be subject to the whim of a presently undefined regulator.

In New Zealand many healthcare professionals regard Complementary Medicine (CM) as supportive of conventional therapy and are aware of its cultural importance[1] which is reflective of the 2019 World Health Organization statement that an increasing number of countries recognize the role of CM within their national health systems.[2]

CM is prevalent and considered effective in New Zealand where 80% of GP’s refer to CM practitioners, 25% of GP’s practice CM[3] [4] and the majority of midwives recommend homeopathy.[5] [6]

However, there is a critical lack of contemporaneous, comprehensive, nationally representative data on CM use within New Zealand.[7]

May I suggest investigation of CM use and expenditure in the New Zealand population as has been conducted in Australia[8] and the United States[9] via utilization of the Medical Research Institute of New Zealand who is committed to enhancing the evidence base for natural therapies[10] as surely this data is required to be able to effectively regulate Natural Health Products within the Therapeutic Products Bill - the stated purpose of which is to protect, promote and improve the health of all New Zealanders. 

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[1] Liu, L., Tang, Y., Baxter, G. D., Yin, H., & Tumilty, S. 2021. Complementary and alternative medicine - practice, attitudes, and knowledge among healthcare professionals in New Zealand: an integrative review. BMC complementary medicine and therapies [online]. 21(1), 63. Available from: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7882070/

[2] WHO global report on traditional and complementary medicine 2019. Geneva: World Health Organization; 2019. Licence: CC BY-NC-SA 3.0 IGO. Available from https://www.who.int/publications/i/item/978924151536

[3] Liu, L., Tang, Y., Baxter, G. D., Yin, H., & Tumilty, S. 2021. Complementary and alternative medicine - practice, attitudes, and knowledge among healthcare professionals in New Zealand: an integrative review. BMC complementary medicine and therapies [online]. 21(1), 63. Available from: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7882070/

[4] 3 Upsdell M, Jaye C. 2011. Engaging with complementary and alternative medicine in general practice. Journal of Primary Health Care [online]. Mar 1;3(1):29-34. Available from: https://pubmed.ncbi.nlm.nih.gov/21359258/

[5] Harding, D. Foureur, M. 2009. New Zealand and Canadian midwives’ use of complementary medicine. Journal of the New Zealand College of Midwives 40, 7-12. Auckland, New Zealand. 

[6] Cottingham P, Adams J, Vempati R, Dunn J, Sibbritt. 2017. The characteristics, experiences and perceptions of homeopaths in New Zealand: results from a national survey of practitioners. Homeopathy [online]. Feb;106(1):11-17. Available from: https://pubmed.ncbi.nlm.nih.gov/28325218/

[7] Lee et al., 2021. Mapping prevalence and patterns of use of, and expenditure on, traditional, complementary and alternative medicine in New Zealand: a scoping review of qualitative and quantitative studies. N Z Med J. Sep3;134(1541):57-74. https://pubmed.ncbi.nlm.nih.gov/34531597

[8] Steel, et al., 2018. Complementary medicine use in the Australian population: Results of a nationally- representative cross-sectional survey. Scientific reports. 8 (1), 17325. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6251890/

[9] Nahin RL, Barnes PM, Stussman BJ. Expenditures on Complementary Health Approaches: United States, 2012. Natl Health Stat Report. 2016 Jun 22;(95):1-11. Available from https://pubmed.ncbi.nlm.nih.gov/27352222/

[10] https://www.mrinz.ac.nz/programmes/complementary-alternative-medicine

Sarah Penrose BSc(hons)Hom. is an Australasian homeopath and can be contacted at goodhealthforgreatlife.com