Selling a Drug


Under the Naturopathy Act, 2007, a naturopath is authorized to perform the controlled act of “prescribing, dispensing, compounding or selling a drug designated in the regulations.”

The designated drugs are listed in table 6 of the General Regulation.  A naturopath may only sell a drug listed in table 6, in accordance with any limitations outlined in the table.  

When selling a drug, the general requirements for performing a controlled act, as outlined on the About Controlled Acts page, do not apply.  Instead, the Part II (Controlled Acts) of the General Regulation establishes the requirements that a naturopath must meet to dispense a drug to a patient:
  • The naturopath can only sell a drug to their own patient, or a patient of another ND in certain circumstances.
  • The drug can only be sold for therapeutic purposes.
  • The naturopath can only sell the drug to a patient or their authorized representative, or a patient or authorized representative of a patient of another naturopath.
  • Where a limitation, route of administration or dosage is indicated in table 6, the naturopath can only sell the drug in accordance with those conditions.
  • The naturopath must advise the patient or their authorized representative that the drug may be available at a pharmacy.
  • The naturopath must have made reasonable inquiries and be satisfied that, i) the patient does not have reasonable or timely access to a pharmacy; ii) the patient would not otherwise buy the drug; iii) the patient does not have the financial resources to obtain the drug if not sold by the naturopath, or iv) the drug is not reasonably available in a pharmacy.
  • The naturopath must not sell the drug if he or she will profit or gain a personal or financial benefit (direct or indirect) from doing so.
  • The naturopath must obtain and store the drug to be sold in accordance with all applicable laws.
  • The naturopath must ensure that the drug to be sold has not expired and will not expire before the date on which the patient is expected to take the last of the drug.
  • The naturopath must retain in the patient’s record (or, if the person is a patient of another naturopath, in their own records) that the drug was sold to the patient or their authorized representative, the price charged and a copy of the prescription.

Selling a Drug to a Non-Patient


A naturopath may sell a drug to a person who is not their patient if:
  • The naturopath possesses the prescription for the drug at the time it is sold.
  • The prescriber is another naturopath;
  • The prescription contains all the information required under the Part II (Controlled Acts) of the General Regulation.
  • The naturopath retains a copy of the prescription in their records.

Additional Education and Training


A naturopath may only sell a drug to a patient if they have met the Standard of Practice for Prescribing. It requires a member to successfully complete a College-approved course and an examination in Therapeutic Prescribing.  The College’s Naturopathic Doctor Registry includes information about whether a member has met this standard.

Selling a Product that Does Not Require a Prescription


A naturopath may sell a product that does not require a prescription (such as a natural health product) to their own patients or patients of other naturopaths (with a recommendation from another naturopath).  This is not covered by the Controlled Acts Regulation. However, naturopaths must also comply with all of the applicable standards of practice of the profession, including, but not necessarily limited to:
  • Dispensing.
  • Recommending Non-scheduled Substances.
  • Conflict of Interest.
  • Fees and Billing.
  • Selling.

What Can or Cannot be Sold?


Substances on the Prescription Drug List or NAPRA Schedule 1 are drugs that require a prescription.  A naturopath can only sell a drug that appears on these lists if it also appears on table 6 of the General Regulation.

Substances that are not on the Prescription Drug List, NAPRA Schedule 1 or table 6 are not drugs. A naturopath may sell those products to their own patient, or a patient of another naturopath who has made a recommendation to the patient, in accordance with the standards of practice for Recommending Non-scheduled Substances.

Table 6


The following includes information in table 6 from the General Regulation.  Every precaution has been made to provide an accurate reproduction. In the case of a discrepancy, defer to the regulation.  Explanatory notes describe how the limitation should apply.  These notes are for information purposes and do not constitute advice from the College of Naturopaths of Ontario.

 Drug  Limitations, routes of administration, dosages  Explanatory note
Colchicine
Must not be sold unless the drug is botanical colchicine, compounded from the corm of the colchicum autumanle.  This limitation requires that only the botanical version of colchicine that is compounded from the corm of colchicum autumnale is sold. 
Digitalis Purpurea and its glycosides  Only if sold in conjunction with monitoring of patient’s serum level by the member.  This drug always requires a prescription.  In addition, a ND must ensure that the patient’s blood serum levels are being monitored when selling this drug.
Estrogen (bioidentical)  Only if sold in topical or suppository form.  This always requires a prescription and may only be sold in a topical or suppository form. 
Folic Acid  Only if sold in oral dosage containing more than 1.0 mg of folic acid per dosage or, where the largest daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 1.0 mg of folic acid.  This is only a drug when sold in a dosage of more than 1 mg per dose or more than 1 mg of daily dose.  A ND may dispense at this level or higher where indicated and a prescription is provided.  Folic acid below 1 mg per dose or per daily dose is not a drug and does not require a prescription. 
L-Tryptophan  Only if sold for patient’s use in oral dosage form at a concentration of more than 220 mg per dosage unit or per daily dose.  Recommended daily dose must not exceed 12g and must be provided in 3 to 4 equally divided doses.  This is only a drug when it is sold in oral dosage at a concentration of more than 220 mg per dosage unit or per daily dose.  The daily dose must not exceed 12g and must be provided in the dosed identified. 
Levocarnitine and its salts  Only if sold for the treatment of primary or secondary levocarnitine deficiency.  This is only a drug when sold for the treatment of primary or secondary levocarnitine deficiency in which case a prescription is required. If recommended for any other condition, it is not a drug and a prescription is not required. 
Pancreatin  Only if sold in a dosage form that provides more than 20,000 USP units of lipase activity per dosage unit or for the treatment of pancreatic exocrine insufficiency.  This drug requires a prescription only when it is sold in a form that provides more than 20,000 USP of lipase activity per dosage or at any dosage amount when sold for the treatment of pancreatic exocrine insufficiency. Lower dosages for other conditions do not require a prescription. 
Pancrelipase  Only if sold in a dosage form that provides more than 20,000 USP units of lipase activity per dosage unit or for the treatment of pancreatic exocrine insufficiency.  This drug requires a prescription only when it is sold at more than 20,000 USP of lipase per dose or when it is being sold for treatment of pancreatic exocrine insufficiency. Lower dosages of this substance used for other conditions are not drugs and may be sold at the discretion of the ND. 
Pilocarpine and its salts  Must not be sold unless, 1. the drug is botanical pilocarpus compounded from the leaves of pilocarpus microphyllus, 2. the member monitors his or her patient’s drug levels during treatment with the drug and, 3. the drug is never sold to treat a patient with glaucoma.  This drug may only be sold in its botanical form as identified and requires that the naturopath monitor the patient’s levels during treatment.  The drug cannot be sold to treat a patient with glaucoma. 
Podophyllotoxin  Must not be sold unless, 1. the drug is botanical podophyllotoxin compounded from podophyllum peltatum and, 2. the drug is never sold to treat a patient with rheumatoid arthritis.  This drug may only be sold in its botanical form and cannot be sold to a patient with rheumatoid arthritis. 
Progesterone (bioidentical form)  Only if sold in a topical or suppository form.  Progesterone requires a prescription and may only be sold in topical or suppository form. 
Rauwolfia  No limitation, etc., specified.   
Thyroid  No limitation, etc., specified.   
Vitamin A
Only if sold in oral dosage containing more than 10,000 International Units of Vitamin A per dosage or, where the largest daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 10,000 International Units of Vitamin A.  Vitamin A requires a prescription only when it is sold for oral use at more than 10,000 IU per dose or where the largest daily does would be more than 10,000 IU.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Vitamin D
Only if sold in oral dosage containing more than 1,000 International Units of Vitamin D per dosage or, where the largest recommended daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 1,000 International Units of Vitamin D.  Vitamin D requires a prescription only when it is sold for oral use at more than 1,000 IU per dose or where the largest daily does would be more than 1,000 IU.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Vitamin K1
Only if sold in oral dosage when the maximum daily dose is more than 0.120 mg.  Vitamin K1 requires a prescription only when it is sold for oral use at more that .120 mg per day.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Vitamin K2  Only if sold in oral dosage when the maximum daily dose is more than 0.120 mg.  Vitamin K2 requires a prescription only when it is sold for oral use at more that .120 mg per day.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Yohimbine and its salts  Must not be sold unless the dispensed drug is botanical yohimbine compounded from the bark of pausinystalia yohimbine.  This is always a drug and always requires a prescription.  It may only be sold in its botanical form as identified. 

For a copy of the General Regulation, see the Resources section of the College’s website.