Importation of Veterinary Products – Position Statement

July 18, 2012

Position

The Canadian Veterinary Medical Association (CVMA) holds that public health, food safety, animal health, and animal welfare are the priority considerations for determining which veterinary products can be imported and used in Canada. 
 
The CVMA supports the licensing and approval process for the sale of veterinary pharmaceuticals through Health Canada’s Veterinary Drug Directorate and use of veterinary biologics through the Canadian Food Inspection Agency’s Canadian Centre for Veterinary Biologics.
 
The CVMA supports the original intention of the Health Canada “own use importation” (OUI) policy that allows for importation of a 90-day supply of human-use drugs for personal use. The CVMA does not support importation of Schedule F Part II veterinary drugs by companion and food animal owners using a ‘non-inclusionary loophole’ of the OUI policy.  OUI importation of veterinary products carries inherent food safety and animal health risks as well as trade risks for food animal products. The CVMA does not support the use of OUI products within on-farm food safety or quality assurance programs (1-4).
 
Background
  1. Health Canada requires that all veterinary pharmaceuticals imported for sale, sold, or advertised in Canada must have a valid Drug Identification Number (DIN).  The CVMA supports this federal regulation as it provides regulatory oversight for these products and contributes to public health, food safety, animal health, and animal welfare.
  2. The OUI policy was established to support human health by permitting individuals to import a 90-day supply of a drug for their own personal use.   Companion and food animal owners access veterinary products through a ‘loophole’ in the OUI policy inferred by the “non-inclusionary” wording.  The CVMA recommends legislative change that closes the loophole in the OUI policy.  Provisions should accommodate animals that are being imported and are accompanied by an appropriate supply of properly labeled pharmaceuticals restricted to the use in the imported animals.
  3. Veterinary products imported into Canada under the OUI policy are not approved by Health Canada and do not meet Canadian label requirements (e.g., bilingual English/French, metric dosing instructions).  This can pose a risk for food safety and animal health and is not congruent with on-farm food safety programs.
  4. The CVMA supports the full enforcement of the Food and Drugs Act and associated Regulations.  The Health of Animals Regulations require that veterinary biologics (e.g., vaccines, antibody products, diagnostic test kits) must be sourced directly from a regulated manufacturing facility and imported under a valid veterinary Biologics Import Permit. Veterinary biologics cannot be legally imported under the OUI policy.
  5. The CVMA encourages a heightened awareness and enforcement by the Canadian Border Services Agency as to the illegal importation of veterinary biologics and Schedule F Part I (prescription) veterinary drugs.
References
  1. Dairy Farmers of Canada - Canadian Quality Milk Program (available at:  http://www.dairyfarmers.ca/what-we-do/programs/canadian-quality-milk)
  2. Canadian Association of Bovine Veterinarians Position Statement on Importation of Veterinary Drugs Unapproved in Canada for Food-Producing Animals (available at: http://www.cabv.ca/file/CABV%20Position%20Statement%20on%20Importation%20of%20Unapproved%20Veterinary%20Drugs%20in%20Food.pdf)
  3. Canadian Pork Council - Canadian Quality Assurance (CQA®) Program (available at: http://www.cqa-aqc.ca/index-e.php)
  4. Guidance Document on the Import Requirements for Health Products under the Food and Drugs Act and its Regulations (Gui-0084) (available at: http://www.hc-sc.gc.ca/dhp-mps/compli-conform/import-export/gui-0084_biu-uif-eng.php)
  5. Final Report of the Task Force on Own Use Importation of Veterinary Drugs (available at: http://canadianveterinarians.net/documents/task-force-report-on-own-use-importation)
  6. Food and Drugs Act and Regulations (available at: http://laws-lois.justice.gc.ca/eng/acts/F-27/)
  7. Health of Animals Act and Regulations (available at: http://laws-lois.justice.gc.ca/eng/acts/H-3.3/)
  8. Uses of Antimicrobials in Food Animals in Canada: Impact of Resistance and Animal Health (available at: http://www.hc-sc.gc.ca/dhp-mps/pubs/vet/amr-ram_final_report-rapport_06-27_cp-pc-eng.php)
(Adopted July 2012)