[NHPB] Question 1

No.

We would recommend that any "Natural" Health Product that claims to have a therapeutic effect fall under the umbrella of the Medicines Act 1981.

If they are meant to treat a specific condition or range of conditions they are being used as medicine and should be regulated as such. There are medicines available OTC which are deemed generally safe, so even within the medicine act there is differentiation between products that are prescription only and those that have been made more widely available and can be used to self-treat minor conditions. I'd also say that they make the assumption that these products are safe, but because they are unregulated and unmonitored it's impossible to tell and any reports such as those that might appear in the medical literature only give an indication that it's happened but not how often. This makes their risks higher than that of pharmaceuticals in my opinion, with those you know precisely what the biochemical effect is and what the reported side-effects/interactions are but with these products it's unknown so in effect the potential risks are infinite.

Where products are used for a health benefit (i.e. vitamins) and not to treat or mitigate an condition they would fall under the remit of these regulations. This would need to be well defined.