The Comfrey Ban

In December 2003, Health Canada banned all products containing the medicinal herb comfrey (Symphytum spp.) because of reports that it contains liver damaging compounds called pyrrolizidines. Many herbalists feel that Health Canada over-reacted in banning products applied externally because pyrrolizidines do not penetrate the skin. Le Guilde des Herboristes in Quebec has organized a national protest to overturn the ban for externally-applied comfrey products. Click here to read the petition.

Note: Seeds and plants are unaffected by the ban. It is legal to grow your own comfrey for personal use. It is legal to grow comfrey commercially also. It is not legal to sell prepared comfrey products such as creams, ointments, pills and teas.

In a letter dated Jan. 21, 2004 Health Canada clarified the ban. The unsigned letter says that only two species of Symphytum are banned, S. asperum and S. x uplandicum; while the common comfrey, Symphytum officinale, and other species are not banned. The letter indicates that the pyrollizidine alkaloid, echimidine, is at the centre of Health Canada’s concerns and that comfrey products must be free of it. Click here to read the letter.

At the National Herb and Spice Conference in Guelph, Ontario, a top official of Health Canada’s Natural Health Products Directorate (NHPD) admitted to a member of the herb industry that the NHPD is unhappy about the way that the comfrey ban was implemented. The ban was imposed by a different branch of Health Canada, the Marketed Health Products Directorate (MHPD), virtually on the eve of the NHPD’s takeover of control of natural health products. The NHPD’s new Natural Health Products Regulations took effect on January 1, 2004. Sources say that the NHPD is powerless to overturn the action of the MHPD.

The current situation leaves industry in the difficult position of having to prove that their products are free of echimidine, the pyrollizidine alkaloid mentioned in Health Canada’s letter of Jan. 21. According to Peter Child of Investigative Science Incorporated, a Burlington, Ontario, consultancy specializing in laboratory testing, reference standards for echimidine are unavailable which makes it difficult for commercial labs to test comfrey products. As of Feb. 2004, at least one comfrey product manufacturer is trying to convince the NHPD to accept herbarium specimens (pressed dried samples of the plant) in lieu of echimidine analysis. But herbarium specimens may not be a reliable indicator of the absence of echimidine. The common and russian comfrey (S. x uplandicum) species are similar botanically and difficult to tell apart.

The current situation effectively means that comfrey products (except seeds and plants) are illegal to sell in Canada.

[Updated Feb. 21, 2004]

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