EU Herbal Campaign -- Response to Concerns
Thanks for raising your concerns about the EU herbals campaign. We had a long discussion of this issue on our team, considering many possible objections. But we spoke with key officials, politicians and professionals involved, and
feel confident that we've taken the right position
.
For clarification purposes,
at no stage of this campaign, has Avaaz implied that it is against regulations
for herbal products,
or that these products are all effective
. Certainly, there have been a few cases of scams involving herbal medicines, and instances where misapplication of herbal medicines have harmed people.
However, the current EU Directive
, which aimed to introduce a simplified registration procedure for herbal medicines
is seriously flawed, rendering many products completely ineligible for registration
and erecting insurmountable hurdles for others.
The Directive creates a situation in which
producers of herbal and other traditional remedies have to bear enormous costs
, years of effort and a lengthy review process to get their products on the market. The costs of tests and submission have been estimated at €100,000 per product, and many manufacturers have hundreds of products.
Large firms may have the resources to jump through these hoops
, but the small scale producers that account for much of the herbal medicine industry do not.
In addition, the rules dictate that traditional herbal medicines
cannot be licensed unless they have been in use for 30 years
, 15 of which in the EU. But
many traditional medicines
sold in the EU market were
registered as "dietary supplements" rather than drugs
so companies
cannot provide valid evidence to prove the safety
and efficacy of their medicinal products in the EU market.
The application of this directive varies across the EU, but
in several countries fewer than 5 herbal products have been registered during the 7 year period
allowed by the EC. This means that
hundreds of herbal products can be taken off the shelves
any day now. Such products aren’t for everyone, but
surveys show that 25% of EU citizens have used herbal products
.
So far not a single non-European traditional medicine products has been approved, as they were not properly included in the new directive. This means that
ayurvedic, Chinese, and other Asian medicine with hundreds of years of use, now cannot be sold as medicines
. This was
recognised by the European Commission itself
in a 2008 report, which
urged extending the Directive
to cover them.
Nothing has been done
about that since apparently the EC lack the expertise and other more pressing agendas such as veterinary medicine have taken priority.
Many Europeans will still want to get hold of herbal remedies for themselves
and their families, and may have to buy them as food supplements, or from the internet, if they can’t find them in pharmacies. That will be less safe, as they won’t be able to get advice on dosage and possible side effects when mixed with other medicines.
These regulations reduce consumer choice, while failing to bring in a comprehensive and effective safety regime, so we've called on the EU to amend the directive
. Our team considered all sides of this argument and spoke to the relevant officials and activists. When polled, the Avaaz community gave an overwhelmingly positive response. You may not agree with this particular campaign, but we hope this response alleviates some of your concerns, and that you’ll continue to support Avaaz in future.
More information:
Alliance for Natural Health Questions and Answers:
http://www.anh-europe.org/news/frequently-asked-questions-about-eu-herbal-registrations-and-bans
ANH and Benefyt Foundation position paper:
http://www.anh-europe.org/files/100916_ANH_Benefyt_abbreviated_position_paper.pdf
European Commission Communication on the Herbal Medicines Directive:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2008:0584:FIN:en:PDF
European Commission press release on the Herbal Medicines Directive:
http://europa.eu/rapid/pressReleasesAction.do?reference=IP/11/510&format=HTML&language=en