The Canadian market for companion animal supplements is smaller than the U.S. market, but it offers something many U.S. brands appreciate: regulatory stability and a clear premium positioning opportunity, according to speakers during a recent National Animal Supplement Council (NASC) webinar, "Beyond Compliance: Unlocking the Canadian Market for U.S. Companion Animal Supplements.”
Ronaldo Avella Lavado and Audrey Lavoie, both of Paul Dick and Associates, walked attendees through Health Canada's veterinary health product, or VHP, notification system, which is the regulatory pathway that governs most companion animal supplements sold in Canada.
Supplements versus drugs
Under Health Canada's rules, what qualifies as veterinary health product (VHP)? According to Lavoie, a low-risk product used to maintain or promote an animal's health and welfare, not to treat, prevent or cure disease. That distinction — maintenance versus treatment — determines whether a product can be sold as a supplement or must be regulated as a drug, a far more burdensome path, said Lavoie.
"A VHP is not just a pet supplement or a pet food with better claims," Lavoie said. "It is an actual regulated low-risk drug category with its own labeling, ingredient notification, GMP and post-market rules."
Both speakers stressed that claims language is the single biggest driver of a product's regulatory classification.
10 takeaways for pet supplements brands looking to grow into Canada
1. The market is smaller than the U.S. but growing quickly. Canada's animal health supplement market is projected to approach US$276 million in value by 2031, roughly a 10% increase from current levels, Lavado said, citing strengthening pet humanization trends and rising veterinary engagement across the country.
2. Claims, not ingredients alone, determine classification. Lavoie said the wording of a claim, not just the ingredient behind it, decides whether Health Canada treats a product as a supplement or a drug. "Claims really are the regulatory engine for this," she said. "They really are what drives this."
3. Broad, functional claims are safest. Words such as "supports," "maintains" and "aids" generally keep a product in supplement territory. "A good typical VHP claim would be something like ‘supports the function of the immune system,’ ‘supports a healthy gut flora,’" Lavoie said, contrasting that with claims naming specific diseases or pathogens, which push a product toward drug classification.
4. Ingredient eligibility is checked at multiple levels. Every active and non-medicinal ingredient, including carriers and excipients, must appear on Health Canada's list of permitted substances for the specific species, route of administration and dose being used, Lavoie said. An ingredient approved for one species or use isn't automatically cleared for another.
5. Missing ingredients can be added, but it takes time. Companies can petition Health Canada to expand an ingredient's listing through a short substance application, typically resolved within about 30 days, or a longer substance application requiring a full safety and literature-based package that can take a month and a half to four months, Lavoie said.
6. Notification timelines are relatively fast once ingredients are cleared. Health Canada is held to a 30-day decision window once a submission passes screening, Lavoie said, though the screening period itself, often two to three weeks, can add unofficial delay.
7. Websites and marketing materials count as label extensions. In one case cited by the speakers, Health Canada denied a VHP classification after finding a study on a client's global website that implied a drug-like claim, even though the material was never submitted to regulators. "Everything besides your label is considered an extension of it," Lavado said. "That includes websites, marketing materials printed in blogs, Instagram, etc."
8. A drug classification is very hard to reverse. Once Health Canada classifies a product as a drug, appealing that decision is difficult, though not impossible, Lavoie said. "It's much easier to go in with everything settled, ready and controlled to avoid that classification than trying to change their mind after that unfortunate classification has been made," she said.
9. Claims, not packaging, determine a treat’s classification. A treat that carries a health claim, such as supporting joint mobility or oral health, is no longer a treat under Canadian rules, Lavado said. "Looking like a treat doesn't make a product a treat, depending on the claims and ingredients that you have," he said.
10. A Canadian representative needs real authority, not just an address. Companies without a Canadian office must designate an individual resident in Canada who can attest to quality systems and post-market surveillance obligations, and who will respond quickly to Health Canada inquiries. "Be mindful that you may miss important communications if that role is assigned to someone who is not equipped to prioritize it," Lavado cautioned.
Getting help
Paul Dick and Associates offers free introductory consultations for companies exploring the Canadian market, Lavado said, with a formal proposal and scope of work developed only after the firm identifies specific regulatory needs. The firm also represents clients before Health Canada, prepares bilingual labeling, and can escalate disputed classifications through its membership in the Canadian Animal Health Institute.
