Invisible Food is a skill share. We operate without an expert to increase our  skills, resilience and self-reliance. We act safely, responsibly, exercising common sense, self-help, and helping each other with respect and tolerance.

With the complexity of the EU Ban on Traditional Herbal Medicinal Products, I wanted to get someone to come and talk to us to get us up to speed on a complex legal issue. I haven’t found that person yet so in the meantime, and with the above in mind,  let’s work with our questions and concerns to raise our awareness ourselves and prick up our critical antennae.

As an exercise, write down your questions surrounding the following statements. Please get in touch with your questions and concerns.  We are planning a project to increase the number of medicinal herbs available to us. Contact us if you are interested in participating!

The EU directive, called the THMPD (Traditional Herbal Medicinal Products Directive) seeks to not just ban the use of herbal remedies but to actually criminalize them — making the growing or keeping of herbs for use in teas just as illegal as those for less conventional use.  Does this mean keeping herbs in your garden for personal use would be illegal?

What else do you want to know about this?

The use of traditional and herbal remedies has already been banned in Canada.

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“Herbal remedies are used throughout the world and have been in use since the beginning of history. This is what the witchhunts were about. How many women were killed during the witchhunt? Power is trying to obliterate our connection with the earth.”

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The Alliance for Natural Health (ANH) is at the forefront of a massive effort to stop what they deem ‘this unprecedented attack’ on the rights of patients. The ANH is taking legal action against this directive, with the assistance of the European Benefyt Foundation (EBF).

Between them they have already managed to raise 90,000 pounds to fight the court case, but they’re requesting your help, too. Because, they say, if people don’t cry out in protest, it will be seen as agreement of the ban, or as lack of interest, which is why a citizens action group has been formed and has been circulating a petition to counter the THMPD Directive.

What else do you want to know about this?

The EU Directive erects high barriers to any herbal remedy that hasn’t been on the market for 30 years — including virtually all Chinese, Ayurvedic, and African traditional medicine. It’s a draconian move that helps drug companies and ignores thousands of years of medical knowledge.

It’s hard to believe, but if a child is sick, and there is a safe and natural herbal remedy for that illness, it may be impossible to find that remedy.

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The EU directive, called the THMPD (Traditional Herbal Medicinal Products Directive) will create major barriers to manufactured herbal remedies, requiring enormous costs,and years of effort. Each herb will cost around £80,000 to register. Pharmaceutical companies have the resources to jump through these hoops but hundreds of small- and medium-sized herbal medicine businesses, across Europe and worldwide, will go bust.

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There are arguments for better regulation of natural medicine, but this draconian directive harms the ability of Europeans to make safe and healthy choices. Let’s stand up for our health, and our right to choose safe herbal medicine.

Dr. Robert Verkerk, executive and scientific director of the UK-based Alliance for Natural Health (ANH) – an NGO promoting natural remedies – said: “At the end of April we plan to challenge the directive first of all in the High Court in London, on the grounds that it is disproportionate, non-transparent and discriminatory. We then hope to have the case referred to the European Court of Justice in Luxembourg.”

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Dr. Robert Verkerk, executive and scientific director of the UK-based Alliance for Natural Health (ANH) – an NGO promoting natural remedies – said: countries such as the Czech Republic and the Netherlands were adopting a liberal approach to implementation which meant that many herbal remedies could be construed as ordinary foodstuffs and thus escape regulation. Think about garlic capsules. This could be seen as foodstuff.

He added that other states, notably the UK and Belgium, were approaching the directive more vigorously, outlawing many more unregistered herbal remedies.

What else do you want to know about this?

The EU Directive erects high barriers to any herbal remedy that hasn’t been on the market for 30 years — including virtually all Chinese, Ayurvedic, and African traditional medicine. It’s a draconian move that helps drug companies and ignores thousands of years of medical knowledge.

What else do you want to know about this?

Examples of remedies threatened following the expiry of the deadline include traditional European herbal cures using hawthorn and meadowsweet in addition to a swathe of herbs used in traditional Indian Ayurvedic, Chinese and Amazonian remedies.

Dr Robert Verkerk said: “The problem is that [synthetic chemical ingredients] are deemed necessary by formulators in order to meet the pharmaceutical stability standards set by the EU directive. Forcing non-European herbal traditions into a European straitjacket would effectively corrupt these great traditions.”

If the ban is allowed to take effect, the ANH says it will effectively eliminate access to phytotherapy, herbalism and all of the traditional plant-based remedies of Indian, Amazonian, African and Chinese cultures. In a very real sense, then, this could also be seen a a cultural attack on specific ethnic groups and ways of life.

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“A new, more appropriate and affordable system of quality control is urgently required to prevent discrimination against the long-standing traditions, and this is something we aim to push for through our planned judicial review,” Verkerk said. 

On the other hand, proponents of the ban claim they are attempting to protect the naive from shoddily produced ‘snake-oil’ elixirs and medicines. They claim that herbal remedies will still be available but that they will simply be safer.

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In France a petition against the directive has been launched by a group of natural remedy stakeholders calling itself ‘Le Collectif pour la Défense de la Médecine Naturelle’. It states the directive imposes a disproportionately costly administrative burden on numerous natural remedies which have existed in Europe for centuries and are not dangerous. A spokesperson for Le Collectif pour la Défense de la Médecine Naturelle said: “If charlatans exist within the sector, that does not justify the persecution of those who rely on numerous producers of plant-based alternative therapies. This type of vigilance will only benefit those who are able to verify that their medicaments are manufactured using certain petrochemical compounds, from which the side effects are incontestably worse.”

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” This is not just about herbal medicine. Big corporations are gaining control over every aspect of our lives, from the food we eat, to the electricity we need in our homes, to our leisure activities and the way we communicate with our fellow human beings.”

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 This following article deals specifically with the situation for Chinese herbalists.

Traditional Chinese medicine firms may face delisting in EU market

http://english.peopledaily.com.cn/90001/90776/90883/7343301.html

The European Union released the “Registration Process Order of Traditional Herbal Medicine” in March 2004 and required enterprises that want to remain in the E.U. market to meet registration standards by March 31, 2011. This order has set a “seven-year limit” for herbal medicine that was imported in the name of food, health care products and even agricultural and sideline native products.

Unfortunately, no Chinese enterprise has completed the registration before the deadline. This also indicates that after missing the seven-year transitional period, traditional Chinese medicine may face the risk of delisting in the E.U. market.

Why did domestic traditional Chinese medicine producers give up the opportunity to apply for the access to the European market? Guo Guiqin, deputy general manager of China Beijing Tongrentang Group Company, said that the main reason is that the registration application fees, particularly the intermediary fees, are too high to afford.

Furthermore, an application standard stipulates that related herbal drug products must already be in medicinal use in the European Union for a period of 15 years preceding the date of the application.

Although traditional Chinese medicine products entered into the E.U. market as early as 1995, domestic traditional Chinese medicine producers regrettably lacked the sense of self-protection and neglected to keep product sales records. Even domestic time-honored producers such as Tongrentang cannot provide evidence to prove that their products have been available on the markets of E.U. members for 15 years.

Although traditional Chinese medicine is very popular in Southeast Asia, traditional Chinese medicine products have often been locked outside of other overseas markets, such as the European Union. It is still possible for traditional Chinese medicine producers to export products to the European Union in the future.

In the long run, however, China’s traditional Chinese medicine industry must follow international practice in terms of product production, processing and distribution to really expand the international market.