Complain to the Competition Bureau and A.S.C.

Please Note: Be sure to CC your complaint to DCVIU_UVCEM@hc-sc.gc.ca in order to get it to Health Canada.  This can be done by making sure you send a copy of your complaint to your email address, available in the Options menu, then forwarding it on to the address above.  To make sure that all eyes have received the complaint, submit it to both the Competition Bureau and Advertising Standards Canada.

You can help stop specific instances of nosodes being advertised as vaccine alternatives by submitting complaints to the Competition Bureau and the Advertising Standards Council using the newly updated Fishbarrel application.

According to Part VII.1 Clause 74.01 of the Canadian Competition Act (R.S.C., 1985, c. C-34), a person advertising a product or service is in violation of the act for deceptive marketing practices according to the following:

“A person engages in reviewable conduct who, for the purpose of promoting, directly or indirectly, the supply or use of a product or for the purpose of promoting, directly or indirectly, any business interest, by any means whatever,

(a) makes a representation to the public that is false or misleading in a material respect;

(b) makes a representation to the public in the form of a statement, warranty or guarantee of the performance, efficacy or length of life of a product that is not based on an adequate and proper test thereof, the proof of which lies on the person making the representation…”

The Advertising Standards of Canada (ASC) has similar language in Provision 8 of the Canadian Code of Advertising Standards:

“Advertisements must not distort the true meaning of statements made by professionals or scientific authorities. Advertising claims must not imply that they have a scientific basis that they do not truly possess. Any scientific, professional or authoritative claims or statements must be applicable to the Canadian context, unless otherwise clearly stated.”

Accordingly, we need to submit complaints to the Competition Bureau and the ASC when homeopaths and naturopaths make unsubstantiated claims for their products and services, especially if they are promoting nosodes as vaccine alternatives. It is important to remember that the NHPD approves these nosode products only “to be used on the advice of a healthcare practitioner”. Any claims that a nosode product can treat or prevent a specific disease like influenza or measles are violations of the Competition Act and are the responsibility of the Competition Bureau to deal with.

Both organisations have limited resources and choose to respond to complaints that are a clear danger to the public. They will also preferentially respond to a complaint that has multiple submissions from different members of the public. A clear message must be sent to these two organisations that this is an important issue they need to deal with. To this end, please search for websites of businesses or practitioners in your local area or province and use the Fishbarrel plugin to submit complaints to either or both of the organisations.

To submit a complaint with Fishbarrel:

  1. Install Fishbarrel 2.1.5 (or newer), available here. Sign up for an account and watch the tutorial available here.
  2. Include the following text when you are complaining to the Competition Bureau:

    I believe that this website is in contravention of Part VII.74.01 of the Competition Act, and that it is making unsupportable scientific claims for these products.

  3. For the complaint to the ASC, include the following text:

    I believe that this website is in contravention of Provision 8 of the Canadian Code of Advertising Standards and that it making unsupportable scientific claims for these products.

  4. Please send a copy of this complaint, as well as any responses from the Competition Bureau or the ASC to info@badsciencewatch.ca so we can track these complaints and watch out for any judgements.
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