Therapeutic or general health claim: where the line sits
How to say what your product does without crossing it.
In short. In Australia, what you say about a product is regulated as tightly as what is in it. Claims on labels, websites, social posts and emails are all treated as advertising of a therapeutic good. The line is between a claim you can support at the level your product is listed for and a claim that implies treating, curing or preventing a disease.
Why the line matters
If your product is represented as being for a therapeutic use, it falls under the Therapeutic Goods Act 1989 and the Therapeutic Goods Advertising Code. Claims that go beyond what your listing allows can lead to compliance action, forced corrections and penalties.
General health claims
For a listed medicine, indications are drawn from the permitted indications and sit at the level of maintaining or supporting health, or relieving mild symptoms. They need to be backed by evidence you hold. Wording matters: a small change in verbs can move a claim from supportive to therapeutic.
Therapeutic claims
Claims about treating, curing or preventing a disease, or about serious conditions, are not available to a listed medicine. Some representations also need specific approval before they can be used at all. If a customer could reasonably read your claim as a promise to treat a condition, treat it as a therapeutic claim.
Where claims show up
The rules apply to more than the pack. Product pages, ads, influencer posts, testimonials, reviews you repost, sales sheets and email campaigns are all advertising. Testimonials and endorsements are held to the same standard as your own words.
A simple test
Ask four questions of every claim. Is it a permitted indication for this product? Do we hold the evidence? Does it imply treating or preventing a disease? Would it still be accurate if the customer read only that line? If any answer is uncertain, rewrite the claim or get it reviewed.
What good looks like
A claims register that lists every claim, where it appears, its evidence and its approval date. It turns a stressful audit into an afternoon of paperwork.
This article is general information, not legal advice. Check the current Advertising Code and TGA guidance before you publish.
- Therapeutic Goods Act 1989 (Cth).
- Therapeutic Goods Advertising Code (No. 2) 2021, as in force.
- Therapeutic Goods (Permissible Indications) Determination, as in force.
- TGA, advertising therapeutic goods guidance: tga.gov.au.
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