A homeopathic remedy which is prepared under the principle of homeopathy in which the active ingredient to be administered is in a concentration not more than 20 parts per million, and the remedy is labelled only with the name of the active ingredient, trade name (if any) and a statement that it is a homeopathic remedy does not normally require Ministerial consent before distribution. The product label or associated advertising material must not contain therapeutic claims or indications for use.
A homeopathic remedy which is labelled or advertised with claims as to its therapeutic purpose is a medicine and subject to the full control of the Medicines legislation.
The term therapeutic purpose is defined under section 4 of the Medicines Act. It includes treatment, prevention and diagnosis of disease, alteration of the shape, structure, size or weight of the human body and otherwise prevention or interference with the normal operation of a physiological function, whether permanently or temporarily, and whether by way of terminating or reducing or postponing, or increasing or accelerating, the operation of that function, or in any other way.
A product is considered to be intended for a therapeutic purpose if a therapeutic claim is stated or implied in the product labelling or promotional material, or where an active ingredient clearly has a pharmacological action.
A statement that a product is intended to give relief from a disease or symptoms associated with a disease is likely to be a therapeutic claim.
A statement relating to the normal nutritional, biochemical or physiological function of a substance is unlikely to be therapeutic claim.
Sterile homeopathic preparations intended for injection or for administration to the eyes are regarded as medicines and therefore subject to the full control of the Medicines legislation.
If cannabis were prepared as an homeopathic remedy as described above with the active ingredient, CBD, in a concentration of 20 parts per million etc it would not be a homeopathic remedy if a therapeutic claim is stated or implied in the product labelling or promotional material or where the active ingredient, CBD, clearly has a pharmacological action.
Whether this low level of concentration would be sufficient to be beneficial to human health or possess any therapeutic purpose, such as pain relief or other pharmacalogical action, and therefore treated as a medicine under the Medicines Act and its Regulations, is unknown to the writer but this account from the NZ Council of Homeopaths states that a cannabis homeopathic remedy was successful where a man had a bad “LSD trip” with continuing symptoms that would not abate.