The EU Directive, Avaaz and the myth of the Mama & Papa herbalists

Avaaz is an online activist movement that campaigns in defence of human rights. They have organised massive petitions against corrective rape, in support of the Egyptian uprising, against the stoning of an Iranian woman and much more. Sometimes their petitions achieve concrete results. Avaaz demonstrates how new communication technologies can be used to hold powerful interests to account. They do good work.

So it is distressing that Avaaz is running a petition that lends support to quacks.

Will they still mate after the European Union Directive stops the sale of Horny Goat Weed?

The petition has collected nearly 600,000 signatories. It calls upon the European Union Commission to amend a directive that goes into force today. The directive, helpfully titled 2004/24/EC, regulates herbal medicines. Renowned debunker Edzard Ernst summarises the purpose of the legislation:

A new EU directive will legislate that a licence for a herbal medicine will be given only if it has been available for a long enough time, if its safety has been established scientifically and if it is of sufficiently high quality. This must be a good thing, because it should reduce the risk to consumers.

But according to Avaaz:

In 1 day, the EU will ban much of herbal medicine, pressing more of us to take pharmaceutical drugs that drive the profits of big Pharma.

The EU Directive erects high barriers to any herbal remedy that hasn't been on the market for 30 years -- including virtually all Chinese, Ayurvedic, and African traditional medicine. It's a draconian move that helps drug companies and ignores thousands of years of medical knowledge.

We need a massive outcry against this. Together, our voices can press the EU Commission to fix the directive, push our national governments to refuse to implement it, and give legitimacy to a legal case before the courts.

The petition states:

We have a right to choose among all remedies and medicines that can keep ourselves and our families healthy.

The EU directive is difficult to understand, written in bureaucratise instead of plain English and can only be properly understood if you understand much other medicines legislation. The EU is frequently criticised for over-regulating people's lives. On the other hand Ernst has criticised the regulations for not going far enough because they do not require proof of efficacy. I don't have strong opinions on this because I don't understand the EU well enough. But the Avaaz petition is misguided for several reasons:

First, it is not clear how the EU directive will help Big Pharma. Because people won't be able to buy a particular herbal product does not imply they will pop a pharmaceutical pill instead. (Incidentally, many big pharmaceutical companies also manufacture dubious alternative remedies.)

Second, the aim of the directive is not to simply ban herbal products but to protect consumers from poorly manufactured products that, for example, have inconsistent doses and formulations. To a lesser extent it offers some protection to consumers from products that make medicinal claims.

Third, because products are herbal does not mean they are safe. The EU often has to issue warnings against herbal products.

Fourth, Avaaz's claim that the directive ignores thousands of years of medical knowledge is not true, because as Avaaz alludes, the directive allows herbal medicines that make minor claims that have been in use for 30 years or more. Nevertheless, blood-letting, trepanning. inducing vomiting and sweating toxins all have a very long history, yet all of them have been discredited. Because a remedy has been around for a long time does not mean it is good. In this regard, Ernst has a point that the EU directive does not go far enough.

Fifth, if Chinese, Ayurvedic, and African traditional medicines can show efficacy, they no doubt will be licensed. That none have been licensed yet is likely a reflection of a lack of evidence or tardy licensing applications.

Sixth, yes we have the right to choose our medicines. We may even poison ourselves if we wish. But sellers of medicines do not have an equivalent right. They are obligated to provide safe and effective products, just as my local electronics shop is obligated to sell televisions that are safe and actually work.

Finally, the underlying myth of the Avaaz petition which permeates attitudes towards alternative medicines generally is that the purveyors of these products are Mama & Papa outfits who just want to give us a bit of wholesome natural goodness. This ignores that the alternative medicine industry is huge and that it has its own lobbyists and propaganda machinery to rival Big Tobacco and Big Pharma. And although there are many small-scale alternative medicine manufacturers and sellers, their quality control and penchant for exaggerated claims are usually far worse than their larger counterparts.

I am fully aware of the problems with Big Pharma. Over the last decade, the Treatment Action Campaign has campaigned successfully against deplorable behaviour by both Big Pharma and alternative medicine sellers. Across the world pharmaceutical companies have to abide by very strict legislative frameworks for a very good reason: we want the pills we pop to be safe and effective. There is no reason why alternative medicine sellers should not be held to the same standards. Sadly, Avaaz has instead come to the aid of this dubious and dangerous industry.

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Comments in chronological order (15 comments)

Roy wrote on 2 May 2011 at 3:26 p.m.:

Nathan, great analysis.

I actually agree that "we" (ordinary people) have a right to choose among all remedies and medicines that can keep ourselves and our families healthy.

But we first have to know for sure that the remedies and medicines actually can do this as promised. And this is where the petition falls short - IMO.

The petition should, if it were really honest and based on a citizen's/consumer's/ordinary person's view, be reworded to say something like: "we have a right to choose, based on complete, full and accurate information, among all safe remedies and medicines that have been proven to be able to keep ourselves and our families healthy."

Harris wrote on 2 May 2011 at 8:24 p.m.:

I concur fully with Roy's comments: consumers should be protected from misleading, false or unsubstantiated claims, yet have a choice to use whatever treatment modality they wish to follow.

Monty West wrote on 3 May 2011 at 10:24 a.m.:

Great article Nathan! I was appalled when I received an email from Avaaz for my vote. They have had some excellent and effective campaigns with politics and human rights which I have supported but this is a major blunder for them. I've written to them but don't feel hopeful. How better to raise this issue?

Nathan Geffen wrote on 3 May 2011 at 10:54 a.m.:

Thanks Monty. I have also written to Avaaz, including a personal email to a former TAC volunteer who went on to work for Avaaz.

I don't know enough about the EU to form a strong opinion on the Directive itself, but I hope more people will write blogs critiquing the alternative medicine backlash against the Directive.

Also, the Avaaz petition talks about launching a court case to stop the Directive. If such a court case is launched, it's critical that EU citizens who support evidence based medicine mobilise against a case that is founded on quackery.

Nathan Geffen wrote on 3 May 2011 at 11:35 a.m.:

I suggest writing a polite email to the following people at Avaaz:

  • Alice Jay:
  • Brett Solomon:
  • Emma Ruby-Sacks:
  • Ben Wikler:

Here is suggested text based on an email I just sent:

Dear Alice, Brett, Emma, Ben

Avaaz does incredible work. I am a big fan. However, your petition on the EU Directive on herbal medicines is misguided and wrong. I've written an article explaining why:

I hope you will consider this issue carefully and perhaps even change your position.



Michael Meadon wrote on 3 May 2011 at 1:06 p.m.:

Completely agreed, Nathan. Steven Novella also wrote a good piece on this topic:

alec dauncey wrote on 4 May 2011 at 10:01 p.m.:

If you want to give Avaaz the benefit of some internet campaign response, their Team are clearly monitoring these facebook discussions: ... note_reply ... hare_reply

If you want to contact Avaaz they then it is here:

Nathan Geffen wrote on 4 May 2011 at 11:09 p.m.:

Thanks Alec. Your comment pointed to this facebook page.

As you can see on the Facebook page, many people are unhappy with Avaaz for this campaign.

Avaaz have also posted this response.

While I take their point that over-regulation might backfire and result in an illegal and completely unregulated herbal medicines market, this is not at all a criticism raised in their petition. Also, I'm not convinced that this is a sufficiently strong criticism of the EU directive. If there's insufficient quality control at the moment, the Directive seems unlikely to make matters worse even if it inadvertently creates an illegal market.

They also repeat some of their poor arguments.

Avaaz states, "But we spoke with key officials, politicians and professionals involved, and feel confident that we've taken the right position."

Have they? Clearly there are officials, politicians and professionals who support the EU directive else it would never have been passed.

I remain disappointed with Avaaz on this issue.

Alistar symes wrote on 6 May 2011 at 11:56 p.m.:

I feel that avaaz is taking the right approach. I am really fed up with this nanny state mentality. Ok maby some things should be controlled. But nearly all herbal medicines are harmless. One example Chinese medicine. It has been used for thousands of years with lots of positive results. Why interfere in peoples lives. EU telling you what you can and cant do. im sick of this.

Roy wrote on 11 May 2011 at 8:12 p.m.:


"In 1991, a cluster of cases of end-stage renal [kidney] failure occurred in otherwise healthy women living in Belgium. At least half of these women subsequently developed urothelial cancer [such as bladder cancer]. They all had attended the same "slimming" clinic in Brussels where they inadvertently received, along with other weight loss agents, the Chinese herb 'Aristolochia fangi'. After its potent nephrotoxicity [kidney damaging] and carcinogenicity [cancer inducing properties] were recognized, the use of aristolochia species was banned in most European countries."

(From a lecture by Professor Arthur Grollman - Distinguished Professor of Pharmacological Sciences and Professor of Medicine at the Stony Brook University School of Medicine, State University of New York.)

Esther wrote on 12 May 2011 at 12:10 p.m.:

I note that none of you say "Thalidomide had some horrible side effects, so let's effectively outlaw all conventional medicine" but this is what your argument amounts to. The EU legislation is a sledgehammer to crack a nut, something of a characteristic of the EU in general where bureaucracy is almost a religion and personal freedom counts for little. I applaud the AVAAZ action, and at least 800,000 other people agree with me. It's too bad AVAAZ don't only support causes which you personally endorse - that doesn't automatically make them unworthy of support!

Nathan Geffen wrote on 12 May 2011 at 12:42 p.m.:

Esther, you have our argument wrong.

What we consistently argue for on this website is that all medicines should meet objective criteria for safety and efficacy irrespective of their paradigm. My understanding of the EU Directive is that it takes a step toward making herbal medicines meet the same standards as other medicines.

You mention thalidomide: It is in large part due to thalidomide that standards for approving medicines have been massively strengthened over the last 4 decades (not always to successful effect as Vioxx shows). All we argue is that herbal and other complementary and alternative medicines should meet these standards.

As to whether the EU over-regulates life generally, that's a completely different debate, beyond the scope of Quackdown. However, based on where I live and my admittedly poor understanding of history, it seems post-war Western Europe has created the most egalitarian, materially comfortable society in history, that it is being emulated now in many other countries and that much of this is due to legislation and regulation. So they surely can't have it all wrong.

Esther wrote on 13 May 2011 at 10:11 a.m.:

I really think that the AVAAZ response says it all. This legislation is not going to make medications safer, it's simply going to push people into buying them from outside of the EU, without the guidance of a qualified practitioner.

Conventional medicine, for all its testing, is far from safe. A comparatively small overdose of paracetamol can produce fatal liver damage but it's a side effect we are prepared to accept because paracetamol is useful in pain management when used correctly. Chemically active substances introduced into the body will always produce a range of effects, some of which you would rather not have!

Clinical trials can really only be said to prove that medicines are safe for use on small groups of healthy young male medical students - the typical volunteers for such trials - or laboratory animals.

The years of experience with other forms of medicine on a wide diversity of human subjects are not seen as valid proof of their efficacy or safety because they don't fit this rigid view of a "proper clinical trial".

As to whether the EU is a mess, I agree it's largely irrelevant to your website, but not to AVAAZ's action. I can only say that Britain at least has had a long tradition of sending its most useless politicians to Brussels in the mistaken belief that they would do less damage there than at home. ;-)

Have a good weekend.

Niels Vandamme wrote on 21 May 2011 at 1:35 p.m.:

Bah, I knew Avaaz couldn't be trusted from the start. They shouldn't have the authority to tell people how things are without sources or discussions by members. That said, much of herbal medicine has been shown by research to work. The Ayurvedic herb aswaganda I'm using now has been shown to act on the neurotransmitters acetylcholine and GABA.

Heidi Damgaard wrote on 28 May 2011 at 11:33 a.m.:

@Roy - read this:

The 1990 case with Aristolochia was a lie! :

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