by John Stan –
It is time for our industry to stand up and demand that a review be done to reverse a decision that has been made by Health Canada about moxa that will negatively impact practitioners and patients.
Eastern Currents has been importing moxa in all its various forms for over 24 years. Recently, the Canada Border Services Agency (CBSA) conducted a standard examination of one of our shipments. The official conducting the review was uncertain how to classify the moxa products in our shipment and decided to contact Health Canada for guidance. Health Canada relayed to him that that since moxa is a plant and there is an intended therapeutic use of this plant, it should be licensed as a Natural Health Product (NHP). This is a completely uneducated response based on misinterpretations of the regulations.
When the plant is used for internal medicine as part of an herbal formula, it is called by its proper name, Ai Ye (Artemesia Vulgarus). It comes either in dried unprocessed leaves, or in concentrated granules. When it is imported as a heating tool, it is called moxa. It comes in a processed woolly form of various degrees of refinement, or rolled up in the shape of cigars, or little rolled pieces attached to a cardboard backing with an adhesive underneath.
I explained to the Border Services agent that this product, moxa, is not ingested and is not a natural health product. If anything, it is more a Class 1 Medical Device and used as a non-invasive heating tool. The agent went back to Health Canada again for further clarification. The response from Health Canada was as follows:
“Moxa are used in Traditional Chinese Medicine (TCM) to heat specific acupuncture points to treat physical conditions, which is considered therapeutic and meets the function aspect of the definition of a NHP as outlined in the NHPR.”
We are shocked by this response and can only assume it was given by someone working in the NNHPD who interpreted the Natural Health Product Regulations (NHPR) incorrectly or with a bias that in no way reflects TCM industry standards. The NHPR deals with botanical medicines, either ingested or applied topically, that have a therapeutic functional effect. The NHPR should not impact how the TCM industry uses this herb, which is in a completely different manner from what the regulations were initially created for.
As we know, the woolly substance we call moxa is formed into various shapes and is used in the TCM industry as a heat source. This heat source could be very focused over an acupuncture point, or it may be used to form a general heat source to warm a region like the abdomen. There are many forms of moxa, but in all cases, the fact is the therapeutic aspect is from the burning substance. It is what I would call a “pre-electrical era” heating tool.
Therefore, if it should be classified by Health Canada, we suggest it should be listed as a Class 1 Medical Device.
Companies that make moxa wool and its related products are more like spinning and grinding companies. They will not meet Health Canada’s requirement that all manufacturers of NHPs must meet Good Manufacturing Practices (GMP) standards. This is where the problem is. The way this product is used and made does not need to meet the GMP standards required for capsules and tablets, as it is an external heating tool.
While not all Canadian importers have undergone this scrutiny by Border Services yet, it will happen over time. There are new systems in place that link Border Services directly to Health Canada so that each shipment is examined. We ask that you not be complacent because you may still be able to purchase moxa from other suppliers in Canada. If action is not taken, we will eventually all lose access to moxa in Canada.
If you use moxa, or even if you don’t but want to protect a health practitioner’s right to practice traditional medicine, then we need you to take action and write to Health Canada and your MPs demanding they reverse their position of classifying Moxa as a NHP.
Please also take a moment to read the companion article to this one called Downward Pressure On Professional Use Products.
Please find linked here some sample letters for you to use:
One specifically to Health Canada regarding the Moxa situation. For the sake of preserving the traditional uses of Moxa, please copy the text into a new document/email, enter your information where needed, sign, and send off to the following Health Canada email address: firstname.lastname@example.org
We’ve also created a sample letter for your MP that addresses the issues raised in this article and the issues addressed in the companion article. Please copy the text, sign, personalize and send to your local MP online.
If you are not a TCM practitioner, but one of our allied health practitioners that wants to show support to the TCM community, please help us by modifying these articles in a way that reflects your support and forward them to Health Canada and your MP.
If you have any questions, please feel free to contact me. Also please share this article with friends and colleagues in the industry. We all need to act!
John Stan, DrTCM
President, Eastern Currents