Veterinary Dealer Licence Fees Clarified

Summary#

This final regulation amends the Licensed Dealers for Controlled Drugs and Narcotics (Veterinary Use) Fees Regulations (SOR/2022-123). It clarifies when dealer licence fees must be paid, tightens the rules on asking for proof to reduce fees, and lets Health Canada request a wider range of documents instead of only costly audited sales records. The item was published on June 22, 2022 and comes into force on the day it is registered.

What it does#

• Sets the basic per-site licence fees at $1,750 and a first-year (reduced) fee of $875. (Note: these base figures are subject to annual Consumer Price Index adjustments; for 2022 those amounts are $1,882.52 and $941.26.)
• Keeps the fee-remission rule that can reduce fees when the fee would be greater than 1.5% of an applicant’s actual gross revenue from veterinary drug activities.
• Clarifies what proof is needed for a remission:
  • Applicants must provide a signed statement of actual gross revenue (and the timing depends on whether they’re in their first year or renewing).
  • If that statement is not enough, the Minister of Health must put the request for more information in writing and may require additional documents such as employee counts, financial statements, tax returns, or business registration documents (in addition to, but not limited to, audited sales records).
• Requires applicants to supply additional information within 90 days of a written request. If they do not, or if the information is still insufficient, remission will not be granted.
• Clarifies payment timing:
  • Fees are payable when the Minister issues a written notice requiring payment.
  • For first-year applicants, the notice will be issued after they provide the revenue statement or during the second month after the end of the calendar year following issuance of their first licence.
  • If additional information was requested, the payment notice is issued after the Minister reviews the information or after the 90-day period expires.

Who's affected#

• Licensed dealers of controlled drugs and narcotics for veterinary use — the businesses that hold or apply for these dealer licences. As of April 2022, there were 12 such licence holders.
• New applicants who are in their first calendar year of conducting licensed activities. On average this affects about 0.75 applicants per year (less than one per year).
• A small number of small businesses — the analysis estimates about 4 small businesses could be affected if they seek fee remission.
• Health Canada and the Minister of Health, since they administer the fees and review remission requests.

Why it matters#

• It removes uncertainty about when invoices will arrive and when fees are due. That helps businesses plan cash flow and avoid surprises.
• It reduces the chance that a small dealer must pay for an expensive, independent audit to justify a fee remission. Health Canada can request less costly documents first.
• For most people and the public, the change has limited impact because very few dealers are affected and the amendments do not change the fee formulas themselves. However, for the small number of new dealers and small businesses, the rules may lower administrative costs or shift payment timing by a couple of months.