A supplement page in Australia may only carry health claims drawn from a fixed government list of permitted indications, and the TGA does not assess most supplements for efficacy before they go on sale. Four claims about vitamins and minerals are prohibited outright, including stating a percentage of the recommended daily intake. Claims about a serious form of a disease need the TGA's prior approval, and claims about cancer, HIV, hepatitis C, sexually transmitted diseases or mental illness cannot be applied for at all. Here is which rule owns which sentence, with the sources.
Is your clinic's supplement page an advertisement?
Almost certainly yes, and this is where most practices start from the wrong place.
The TGA rules on advertising therapeutic goods do not care whether you call the page a shop, a dispensary, a resource or patient education. They attach to promoting the use or supply of a therapeutic good. A supplement sold from your front desk is a therapeutic good. So the page describing it is an advertisement, and so is the Instagram post, the emailed newsletter, and the printed card in the waiting room.
That matters because clinics tend to write these pages in a completely different voice from the rest of the site. The service pages get checked. The retail shelf does not. It gets copied from the supplier's product page, which was written for a different audience under a different risk appetite, and pasted in.
Everything below is about what those pages are allowed to say. The general shape of the rules is in our guide to the TGA Advertising Code in 2026. This post is the supplement-specific layer underneath it.
Does the TGA check that a supplement works?
For most supplements on an Australian shelf, no. And the TGA says so in plain words.
Its guidance on permitted indications opens with this:
"As listed medicines are not evaluated, the Therapeutic Goods Administration (TGA) uses a variety of mechanisms to help ensure that they are of high quality and used safely by consumers."
Read the first clause on its own. Listed medicines are not evaluated. Most supplements are listed medicines. The sponsor certifies that they hold evidence for the claims. Nobody at the TGA reads that evidence before the product goes on sale.
There are three tiers, and the number on the label tells you which one you are looking at.
| Label | What it is | Was efficacy assessed before market? |
|---|---|---|
| AUST L | Listed medicine. Low-risk ingredients, claims from the permitted indications list. | No. The sponsor certifies they hold the evidence. |
| AUST L(A) | Assessed listed medicine. Permissible ingredients, but approved for higher-level claims. | Yes, for the approved claims. |
| AUST R | Registered medicine. Higher risk. | Yes, individually evaluated. |
This is the single most useful fact in the whole area, and it cuts both ways. It means a practice cannot lean on the presence of an AUST L number as though it were a tick of approval. It also means the copy has to work harder, because the regulator has deliberately put the guardrail somewhere else: not on the evidence, on the words.
Where do supplement claims have to come from?
From a list. A specific government list, and nowhere else.
The TGA's rule is that listed medicines "must only use indications drawn exclusively from a list of pre-approved 'permitted indications'". That list lives in the Therapeutic Goods (Permissible Indications) Determination, and it is maintained by the TGA.
The word doing the work there is exclusively. This is not a code of principles you interpret. It is a menu. If the claim you want to make is not on the menu, the answer is not to phrase it more carefully. The answer is that a listed medicine cannot carry it, and a higher assessment pathway is the only route.
The permitted indications also have a fixed grammar. Each one contains a therapeutic action and a therapeutic target, and they generally form a complete sentence. Some carry a target qualifier, and the TGA's guidance is explicit about what that qualifier is for: it ensures the indication is not referring to a serious form of a disease, disorder or condition.
So the word mild sitting in front of a condition on a supplement label is not marketing softening. It is a load-bearing part of a legally defined phrase, and deleting it in a rewrite changes what the claim legally is.
What this means for a rewrite. Copy that improves the rhythm of a permitted indication may have destroyed it. Before you edit any sentence on a supplement page, find out whether it is a permitted indication being quoted. If it is, the words are fixed and your job is everything around them.
Which vitamin claims are banned outright?
Four of them, and the first is on nearly every supplement page in the country.
The Therapeutic Goods Regulations set out prohibited representations that apply to particular kinds of goods. Vitamins and minerals have their own entry. These are the representations it names.
| Prohibited representation about a vitamin or mineral | What it looks like in real copy |
|---|---|
| The amount present, expressed as a percentage or proportion of the recommended daily or dietary intake or allowance | "Provides 150% of your recommended daily intake of vitamin C" |
| The recommended daily or dietary intake or allowance itself, unless it is current and sourced from the National Health and Medical Research Council | Any RDI figure lifted from a supplier sheet or an overseas source |
| That the product is a substitute for good nutrition or a balanced diet | "Covers what your diet misses" |
| That the product is superior to, or more beneficial in any way than, dietary nutrients | "More bioavailable than food sources" |
The complete list is in Part 1 of Schedule 2 of the Therapeutic Goods Regulations 1990.
The first row is the one that catches practices, and the reason is mechanical rather than reckless. The percentage is printed on the manufacturer's own product page. Somebody building the clinic's shop copies the product description across. The manufacturer's label may be operating under different rules from the clinic's advertisement, and nobody in the chain stopped to check.
The fourth row is the one that catches good intentions. A practitioner who genuinely believes a form of magnesium absorbs better than the dietary version, and says so, has made a prohibited representation. Being right is not a defence to this one. The representation itself is what the rule prohibits.
What is a restricted representation?
A reference to a serious form of a disease, condition, ailment or defect. And the TGA's definition of serious is more useful than most people expect.
"The definition of a 'serious form' of a condition, ailment, disease or defect are those which require a health professional to diagnose, follow-up or treat."
That is a workable test you can apply to your own copy without a lawyer. If the thing you are naming is something a patient would need a practitioner to diagnose or manage, you are probably in restricted representation territory.
You cannot use one in any form of advertising unless you have the TGA's prior approval or permission, or it forms part of a required health warning. The TGA states that significant fines and penalties apply for using restricted or prohibited representations without that approval in place first.
Two details worth carrying around. Pregnancy is not a restricted representation, unless it is a pregnancy with a medical, obstetric or surgical complication. And there are exactly two substance-based exemptions sitting inside the permitted indications list, granted on the basis of public health importance, safe history of use and a well-established evidence base:
- vitamin D with calcium, referring to osteoporosis
- folic acid, referring to neural tube defects
The TGA's guidance is blunt about everything outside those two. All other indications that refer to a restricted representation require assessment and approval through a pre-market assessment pathway.
Which claims can never be approved at all?
Prohibited representations. These are a step beyond restricted, and you cannot apply to use them.
A prohibited representation concerns the treatment, cure, prevention, diagnosis including screening, or monitoring of, or the susceptibility or pre-disposition to, any of these:
- neoplastic diseases, which the TGA glosses as all types of cancer
- sexually transmitted diseases
- HIV or AIDS
- hepatitis C
- mental illness
Representations about abortifacient action are prohibited as well.
The TGA can permit these in a specific advertisement where it is necessary for public health or for the appropriate use of the goods, but you cannot apply for that. It is granted, not requested.
Mental illness is the entry that catches wellness-oriented clinics, and it needs a careful read rather than a panicked one. The prohibition attaches to treatment, cure, prevention, diagnosis, monitoring, susceptibility or pre-disposition. A permitted indication about supporting general wellbeing is a different sentence from a claim to treat or prevent a mental illness. The gap between those two sentences is narrow, it is easy to cross in a headline, and crossing it is the version with penalties attached.
What happens when AHPRA and the TGA both apply?
You wear both jackets at once, and clearing one regulator tells you nothing about the other.
If a registered practitioner sells supplements, or a business advertising a regulated health service does, then two rulebooks are live on the same page. The TGA governs what you may claim about the product. The National Law governs the advertising of the health service sitting around it.
| The sentence on your page | Which regulator owns it |
|---|---|
| What the supplement does | TGA. Permitted indications only. |
| The percentage of the daily intake it provides | TGA. Prohibited representation. |
| A patient saying the supplement fixed their symptom | Both. A testimonial about clinical care under the National Law, and a claim about the product under the TGA rules. |
| "Recommended by our practitioners" | Both, and worth advice before you publish it. |
| What results a patient can expect | Both. The National Law prohibits advertising that creates an unreasonable expectation of beneficial treatment. |
This is the same double-jacket problem we mapped for complementary medicine in AHPRA advertising for naturopaths, and it behaves the same way here. The regulators do not coordinate. Passing one audit is not a defence in the other's process.
What should you fix on your supplement pages this week?
Five checks, in the order that finds the most problems fastest.
- Search your whole site for a percent sign next to a nutrient. Every "provides 100% of" is a prohibited representation. This one check usually clears the largest number of breaches in the least time.
- Find every RDI or daily intake figure and trace its source. If it did not come from the National Health and Medical Research Council, and it is not current, it cannot stay.
- Hunt the better-than-food sentences. Anything comparing the product favourably with dietary nutrients, or positioning it as cover for an imperfect diet, is on the prohibited list.
- Check every health claim against the permitted indications list. Not against your own judgment of whether it is true. Against the list. If it is not there, it does not go on a listed medicine.
- Apply the serious-form test to every condition you name. If a patient would need a practitioner to diagnose or manage it, treat the sentence as a restricted representation until you have established otherwise.
None of this stops a practice selling supplements or writing about them well. It moves the work to a different place. The claim is fixed by the regulator, so the persuasion has to live in everything else on the page: who you are, how you decide what to stock, what happens at the consultation, and why a patient would trust your judgment over a marketplace listing.
That is a harder brief than copying the supplier's blurb. It is also the only version that is both legal and worth reading.
This article explains a regulatory landscape. It is general information, not legal advice. If you are unsure which rules apply to your products or your practice, get advice from a health law practitioner or your professional association.
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Amisha Sharma
Amisha Sharma writes compliance checked healthcare copy for Australian practices and agencies. She built GhostRank, the 226 check audit engine, and every piece she ships carries its evidence report.
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