Thank you to the chair and the committee for providing me with the opportunity to speak today.

My name is Peter Maddox, and I'm the president of the Direct Sellers Association of Canada. DSA Canada was founded in 1954. We have over 60 direct seller and supplier member companies, including well-known brands such as Mary Kay, Arbonne, Avon, Usana, Shaklee, SoulLife and Immunotec. We represent a diverse and dynamic industry that is integral to Canadian entrepreneurship, and we care deeply about customer service and consumer safety.

Every year, the direct-selling sales channel accounts for an estimated $3.4 billion in retail sales and contributes $1.5 billion in personal revenue to the approximately one million Canadians who participate as independent sales consultants, 84% of whom are women. Many DSA Canada member companies include NHPs in their product portfolios. Around 45% of current independent sales consultants gain at least some income from selling NHPs.

Our focus today is to raise concerns about process—specifically, the process followed when Bill C-47 brought Vanessa's Law to the NHP space and, more broadly, how this is symptomatic of the imperfect process that industry has seen in the federal regulation of NHPs, which has led to a lack of transparency, clarity and certainty for all stakeholders. This is creating unnecessary economic barriers and risks for both consumers and businesses. Vanessa's Law, including mandatory recalls and label changes, was introduced to NHPs via an omnibus budget bill, without being open to significant levels of debate or consultation.

We question the value of adding these measures when existing tools, such as stop-sales and inspections, are infrequently utilized. Effective regulation must be backed by consistent and proactive enforcement. Otherwise, existing rules and the introduction of new regulation have nominal impact. With the introduction of Vanessa's Law, along with other proposed Health Canada initiatives, such as cost recovery, we were disappointed by the lack of consultation and economic impact assessments, including studies of the impact on women. Our desire is for a world-class NHP system built on best practice, co-operation among all stakeholders, the use of research and data, and an intention to balance the needs of consumers, industry and other impacted parties. Slipping a new requirement into existence via an omnibus budget bill is one piece of evidence that this is not happening.

Uncertainty and lack of clarity in regulatory processes are causing Canadian direct-selling companies to struggle with product innovation, pushing our multinational businesses to consider reducing their product offerings or exiting the Canadian market. Furthermore, international NHP direct-selling companies not yet operating in Canada are choosing to expand into other markets instead. The result is diminished investment, employment and tax contributions. Uniquely in the direct-selling industry, it also reduces earning opportunities for the many Canadians who participate in our channel as a side hustle or gig for supplementary income. A lack of consistency, timeliness and predictability in decision-making, program implementation and ongoing operations is hurting the economy, reducing consumer choice and raising costs.

One area where collective action could help improve the situation for Canadian entrepreneurs and consumers is an enforcement focus on international businesses that undertake commercial activity under the auspices of Canada's personal use exemption. If we do not invest in policing these unregulated products entering Canada, more companies will see the personal use exemption as a way to distribute products to end-consumers without having to do the right thing and go through the Canadian regulatory process. Unapproved products create potential health risks for consumers and punish companies that are deeply committed to the Canadian market while operating here in good faith and good practice.

In closing, DSA Canada supports Bill C-368 as a means of resetting and realigning the NHP regulatory environment, enabling all stakeholders to work together to create a system that prioritizes consumer safety while fostering economic growth.

Thank you, and I welcome your questions.