Chinese Herbal Formulas and Chiropractic Scope: Is There an Issue?

An ATCMA Update

ATCMA has heard concerns from members about CCHPBC’s new Clinical Practice Standard: Designing, Compounding and Dispensing Herbal Medicines and Natural Health Products, and whether it allows chiropractors to prescribe Chinese herbal formulas or expands their scope of practice.

We have reviewed the document, considered the concerns raised, and spoken with the BC Chiropractic Association to better understand the issue. Based on our review, we have found that the clinical standard does not expand chiropractic scope of practice and does not newly authorize chiropractors to prescribe Chinese herbal formulas.

Here is what TCM practitioners should know.

1. Chiropractors Are Not Included in Clinical Practice Standards Principles 4 and 5

The new clinical practice standard contains five principles addressing the safe and ethical use of herbal medicines and natural health products.

Chiropractors are included in some provisions relating to recommending and dispensing natural health products. However, they are not included in the licence classes listed under Principle 4, which addresses designing herbal medicines for compounding, or Principle 5, which addresses compounding herbal medicines.

These provisions identify the applicable TCM and naturopathic medicine licence classes, not chiropractic licensees.

This is an important distinction. The document does not identify chiropractors as authorized to design individualized herbal formulas for compounding or to compound those formulas under these standards.

2. The Clinical Practice Standard Does Not Override the Regulations

A clinical practice standard is not the same as a regulation enacted by the BC Ministry of Health.

The Complementary Health Professionals Regulation establishes the scope of practice for each regulated profession. The chiropractic scope of practice is defined as:

“(a) assessing the physical health status of patients for the purpose of providing the health services referred to in paragraph (b);

(b) preventing, treating and managing diseases, disorders and conditions of the neuromusculoskeletal system by manipulating or adjusting the spine and joint (i) by manual methods, or (ii) by using devices directly related to the manipulation or adjustment;

(c) advising on (i) the health and care of the spine, joints and tissue associated with the spine or joints, and (ii) the effect on the neuromusculoskeletal system of the matters referred to in subparagraph (i).”

A CCHPBC clinical practice standard does not replace or override this regulatory framework. Chiropractors must continue to practise within their authorized scope, as well as within their individual knowledge, skill, training, and competence.

The inclusion of chiropractors in a clinical practice standard concerning natural health products should not be interpreted as an expansion of their scope of practice.

3. Chiropractors Have Previously Been Able to Recommend Supplements Within Their Scope

Chiropractors have been able to recommend supplements, including pre-made herbal formulas, related to the neuromusculoskeletal system, provided they do so within their own knowledge, skill, and training.

The new standard establishes expectations for safe practice, including patient education, consideration of potential interactions and adverse effects, and appropriate quality assurance when products are dispensed or stored.

These professional requirements do not, in themselves, establish new authority to prescribe Chinese herbal formulas.

ATCMA has also spoken with the BC Chiropractic Association, which confirmed that chiropractors are not seeking changes to their scope of practice regarding the recommendation of supplements.

4. Chiropractors Still Cannot Make TCM Diagnoses or Design and Compound Chinese Herbal Formulas

The distinction between recommending a supplement and practising Chinese herbal medicine is important.

Importantly, chiropractors are not included in Principles 4 and 5, which address designing herbal medicines for compounding and compounding herbal medicines and natural health products. Chiropractors still cannot make a Traditional Chinese Medicine (TCM) diagnosis or design and compound Chinese herbal formulas under their chiropractic scope of practice.

Chiropractors remain unable to make a TCM diagnosis or design and compound individualized Chinese herbal formulas under their chiropractic scope of practice.

The clinical practice standard does not change that distinction. TCM practitioners should not interpret the document as granting chiropractors new authority to practise these aspects of TCM.

5. Should Registered Acupuncturists Be Able to Make Natural Health Product Recommendations?

This issue also raises a broader question: should Licensed Acupuncturists (R.Ac.s) be permitted to make natural health product (NHP) recommendations under the same principles that apply to chiropractors?

We are looking into comparing the education and training chiropractors receive in nutrition and supplementation with the corresponding training of acupuncturists. This will help us better understand the professional and regulatory considerations involved in determining what NHP recommendation activities are appropriate for R.Ac.s.

Any discussion of expanding or clarifying these activities must consider practitioner training, competence, patient safety, and the existing regulatory framework. ATCMA will continue to examine these questions as part of our broader work to ensure that the training and expertise of TCM practitioners are appropriately recognized.

6. Who’s Responsible for the Clinical Standard?

CCHPBC closed its feedback period on this Clinical Practice Standard on October 9, 2026. While ATCMA has heard concerns from members and reviewed the document, our advocacy efforts have focused on a broader and more consequential issue: pushing CCHPBC to restore the restricted activity for prescribing/designing Chinese herbal formulas.

The concern is not that chiropractors have suddenly gained new authority to recommend natural health products. Rather, following the removal of the restricted activity from the regulations, members of the general public who are not licensed healthcare professionals can prescribe Chinese herbal remedies. This raises important questions about public protection and the distinction between the training and accountability of regulated TCM practitioners and the activities of unlicensed individuals.

It is also important to understand who is responsible for this Clinical Practice Standard. CCHPBC, as the regulatory college, is responsible for developing and setting its clinical standards. The BC government and the Ministry of Health are not the decision-makers for individual college clinical standards. Regulatory colleges operate at arm’s length from government, with responsibility for regulating their professions in the public interest.

For questions or concerns about how this standard is interpreted or applied, CCHPBC is therefore the appropriate body to contact. For the separate issue of restoring the restricted activity for Chinese herbal formula prescribing and design, ATCMA will continue to advocate with the BC government for the changes needed to protect the public and recognize the training and expertise of regulated TCM professionals.

This Is Part of ATCMA's Work

Regulatory changes can be complex, and concerns can spread quickly when the implications of a document are unclear. Our responsibility is to examine the details, seek clarification, communicate with relevant organizations, and help members distinguish between genuine changes to professional scope and interpretations that are not supported by the available evidence.

ATCMA will continue to advocate for the interests of TCM practitioners in BC, including protecting the integrity of our profession and ensuring that our scope of practice is clearly defined and appropriately recognized.

This is the work ATCMA does on behalf of its members: reviewing regulatory developments, asking questions, engaging with other organizations, and helping practitioners understand what changes mean for their professional practice.

Your membership helps support this ongoing advocacy and representation for TCM practitioners across British Columbia.