I thought I’d write to the MHRA and give them my two penn’orth. I decided to focus on the labelling of magic beans.
Homeopathic products, whatever scheme they are regulated under, should be labelled in such a way that consumers are not misled as to their nature. Products diluted above 24X or 12C are unlikely to contain a single molecule of the alleged active ingredient. If a product is labelled as “Arnica 30C”, it implies that the product actually contains some arnica. This is misleading to potential consumers.
Perhaps all homeopathic products at dilutions higher than 12C should be labelled “contains no active ingredient” and those at 12C and below should be labelled “may contain no active ingredient”.
Evidence of Efficacy
Products that come under the National Rules Scheme should require a higher standard of evidence of efficacy than at present [see below for more]. These products should be labelled to indicate the possibility that no active ingredient is present as per my above comments.
Products that come under the Simplified Scheme should be clearly labelled to indicate that no evidence of efficacy has been required or provided for the licensing of the product. I think that it would be reasonable to require a statement along the lines of “There is no good evidence that this product is effective“.
I write a blog called Stuff And Nonsense, in which I am sometimes critical of pseudoscientific nonsense masquerading as medicine.
In the post I mention in the introduction, Zeno links to this PDF. This is apparently the only homeopathic product in the National Rules Scheme category. Here’s something from the lay summary:
Arnicare Arnica 30c pillules is a homeopathic medicinal product used within the homeopathic tradition for the symptomatic relief of sprains, muscular aches and bruising and swelling after contusions. The pillules’ active ingredient is Arnica montana 30c. These indications are based on:
– Published scientific literature
– Homeopathic provings (a homeopathic proving is the method by which the profile of a homeopathic remedy is determined and can be used to establish its potential applications.)
No new or unexpected safety concerns arose from this application and it was, therefore, decided that a homeopathic marketing authorisation could be granted.
The italics are mine. I would question the wisdom of considering homeopathic provings in the course of making a decision on the regulation of a homeopathic product.
I’m not sure what published scientific literature the MHRA reviewed in the course of making their decision, but I do hope that they were aware of this systematic review.
I have referred throughout to “homeopathic products” rather than “remedies” or “medicine”. This is deliberate.
I’ve previously written A Beginners Guide To Homeopathy and a post on Cochrane Reviews Of Homeopathy. (Note for connoisseurs of the homeopathy advocate: the comment threads on both posts feature Oliver Dowding.)