How To Market Supplements In Australia Under The TGA Rules

Start by working out what you actually sell, because the rules follow the product. A vitamin entered on the Australian Register of Therapeutic Goods (ARTG) is a therapeutic good, and its advertising falls under the Therapeutic Goods Advertising Code on every channel: your site, your emails, your posts and the comments under them. A protein powder sold as a food sits under the Food Standards Code, where Standard 1.2.7 covers health claims.

Once you know which side of that line each product sits on, the marketing plan gets much simpler. You can see what can be said, and who can say it.

What you can claim

The claims in your advertising have to match the product's entry on the ARTG. Three more rules sit on top of that:

• You cannot imply the TGA or the government has endorsed the product, so "TGA approved" is out.
• Claims about serious diseases are restricted representations, and they need TGA approval before you use them.
• Complementary medicine ads carry a mandatory statement telling people to read the label and follow the directions for use.

Keep a claims register for this. One sheet per product holds the AUST L number, the ARTG indications, the approved wording and who signed it off, and every brief, caption and ad pulls its wording from that sheet. Have your regulatory adviser approve it once, and new campaigns stop needing a fresh argument. We write this as marketers, so take the legal calls to that adviser.

Testimonials and endorsements

The TGA treats these as two different things, and every influencer deal turns on the difference.

A testimonial is someone saying they used the product themselves, and it cannot be paid for. An endorsement is support or approval, such as a person recommending the product for its listed purpose, and that can be paid for when the payment is disclosed in the ad.

Payment here is broad. The TGA counts money, free or discounted products, gifts, flights, accommodation and the promise of future benefits. So a creator you have paid can recommend the product within its indications and disclose the deal, but cannot tell the camera how it changed their sleep.

Current or former health practitioners, health professionals and medical researchers cannot give either one. Neither can a hospital or a government body, which rules out the white-coat ad.

Reviews and comments

A review on your site or a comment on your post is part of your advertising, and you answer for it even if you did not write it and do not know the person who did. Before using a testimonial you also have to confirm who made it and that its content complies.

Two things follow in practice. Switch off any review app that offers a discount in exchange for a review, because that discount counts as payment. Then have someone read comments every day and remove anything that claims a result the product is not listed for. Hashtags count as well, so #weightloss on a vitamin post can turn it into a claim.

A channel mix that holds up

Every channel still runs off the claims register. The mix below spreads the risk so one rejected ad or account review does not stop sales:

• Search and education: articles on ingredients, dosage and how to read a label. An article promoting a product's benefits is advertising, so it uses register wording too.
• Email and SMS: your own customers, reached directly, with consent under the Spam Act 2003.
• Paid social: lead with the product, the routine, where the ingredients come from and how it is made. Meta's unsafe substances standard and Google's healthcare and medicines policy sit on top of the TGA rules, so a compliant ad can still be rejected.
• Creators: the product in a real routine, with the deal disclosed and no personal result described.
• PR and retail: launches and new pharmacy or retail listings give you a story that needs no health claim at all.

What to measure

Tight claim rules shrink what an ad can say, so creative supply becomes the limit on paid. Plan for more angles and more shoots than the same brand would need in a looser category.

Then judge acquisition on repeat orders rather than the first sale. Supplements are a habit purchase, so the numbers that matter are how many first-time buyers reorder and how long it takes the second order to pay back the cost of the first.

A claims register takes an afternoon to start, and every campaign afterwards moves faster for it.