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Re Traditional Herbal Medicinal Products Directive (THMPD) (2004/24/EC).
I am extremely concerned about the unfair, disproportionate, and meddlesome EU Traditional Herbal Medicinal Products Directive (THMPD) (2004/24/EC) which comes into force on April 30th2011, and the affects it may have on my health and my right to choose my own medication.
THMPD legislation requires that so-called medicinal herbs must be licensed in order to remain on the market after April 30thof this year. However, the costs associated with licensing are horrendous – around £60-80,000 per single herb and much more for a multiherb formula. These costs are not recoverable for all but the largest of companies, and even they have only been prepared to seek licences for a tiny handful of herbs. Although the MHRA claim that that there have been many licences granted, many have simply been duplication of the same herb multiple times, and I understand at the moment it is estimated that only a tiny proportion of currently available herbs will still be available once the ban comes into force. Polyherbal products are set to disappear almost entirely.
I am aware of the recent announcement by the UK government to introduce statutory regulation of herbalists, thus allowing them to continue to prescribe unlicensed herbal remedies, but as I am not able or willing to spend £50 to £100 for an appointment with a herbalist just to buy a few herbs which I have been buying for a long time, this “concession” is of no meaning to me whatsoever - at least not unless the UK Department of Health is willing to provide me with the funds to see a practitioner on a regular and ongoing basis and the inevitable increased cost of the herbs. This conccessional appearts to be merely TYxccxcvffgffg T Thi Thiasdsdsa This This "concession" may be a green light to enable a handful of wealthy people to continue to buy herbs, providing they can find a practitioner, but it does not help me.
I think it is clear that the government and the EU commission need to URGENTLY re-think its position in order to allow me to continue to take the herbs of my choice, so that I do not have to purchase them from outside the EU or on the black market. That means having a regulatory regime that is sufficiently low in cost to be realistically affordable as to allow all herbal companies, most of which are small companies, to continue to supply a wide range of herbs at a reasonable cost to me as a consumer.
The fact is that the vast majority of herbs have a remarkable safety record compared with all pharmaceutical drugs both prescription and non prescription (and those that do not are already banned), with an adverse reaction rate around 1/3000th as frequent as conventional medications. Of the incredibly rare instances of adverse reactions, most have been with herbs that are banned already, or compounds which have been intentionally adulterated, which is a trading standards issue, which does not need what amounts to a virtual blanket ban on most herbs on the market. I beleive that THMPD is repressive, disproportionate and an affront to my right to choose to use herbs for my health.
If writing to a government health minister
Could you please tell me what genuine steps you are taking to protect my basic right to choose my own medication. I am not interested in the "compromise" referred to above, as it does not help me. I feel very strongly that this right should be protected, to the degree that it will influence my future voting intentions.
If you are writing to an M.P.
Could you please tell me what steps you are taking to urge the government to protect my basic right to choose my own medication. I am not interested in the "compromise" referred to above, as it does not help me. I feel very strongly that this right should be protected, to the degree that it will influence my future voting intentions.
If you are writing to an M.E.P.
Could you please tell me what steps you are taking to urge the EU commission to re-think this directive, and the government in my own country to protect my basic right to choose my own medication. I am not interested in the "compromise" referred to above, as it does not help me. I feel very strongly that this right should be protected, to the degree that it will influence my future voting intentions.
If you are writing to the EU Commission John Dalli
I would like you to consider my concerns and my human rights, and consider the possibility of scrapping THMPD altogether in favour of a fairer and less disporportionate directive.
Insert your name here
Optional bits of the letter
You may want to something like: 'I personally take x, y and z herb......I beleive that not being able to obtain these herbs poses a real threat to my health..... I demand my right to continue to be able to continue to purchase these herbs'.
(If you are religious),
You may want to say it offends your religious views:
'We causeth the grass to grow for the cattle, and herb for the service of man.' (Psalm 104;14)
“The leaves of the tree are for the healing of the nations” (Revelation 22:2)
"The fruit thereof shall be for meat, and the leaf thereof shall be for medicine” (Ezekiel 47:12)
(but not if you are an EU citizen!).
Before sending any letters...
Note,' culinary' as opposed to 'medicinal' herbs (this appears to mean a herb which someone in authority deems tastes nice) like garlic and ginger are not subject to licensing. Also the following herbs have received licenses in the UK (May 15th 2011).
1. Agnus Castus
3. Black Cohosh
4. Devil’s Claw
7. Ginkgo Biloba
8. Horse Chestnut
9. Milk Thistle
10. Norway Spruce
16. Saw Palmetto
17. St John’s Wort
Please note, the price of the licensed herbs are generally around double or triple the price they were previously sold for, and because in many cases are not being produced by genuine health companies, tend to be concentrated extracts in an alcohol base rather than natural wild crafted whole leaf products. This does not open the door to other companues to produce the same herb - only the one that paid up the money and time to get the license. This is great for a few large companies, and puts the rest out of business.