Your website is part of your label: how the TGA looks at overall presentation

In short. Under the Therapeutic Goods Act, a medicine's presentation includes its name, label, packaging and the advertising and information around it. The TGA looks at that whole picture. If your label is careful but your product page, social posts or reviews suggest a use the product is not listed for, the overall presentation can still fail.

What counts as presentation

In its recent guidance on NAD and NMN products, the TGA lists the elements it considers: the ARTG entry, the name, the label including symbols, pictures and logos, the packaging, dosage form, claims made in connection with the medicine, and advertising material such as websites, blogs, social media, consumer reviews and testimonials.

The customer's first impression wins

The guidance points to a Tribunal decision finding that a consumer is unlikely to analyse each part of a label and instead forms an overall impression from the common thread running through it. The practical result is that corrective information shown separately or less prominently does not overcome a misleading primary message from more prominent elements.

Where this goes wrong

The name does the heavy lifting. A name and image that suggest an ingredient or benefit can outweigh a correct ingredient panel.

Educational pages that drift. A page can start with a mechanism and end up implying that the product helps with ageing or a serious disease. The TGA's examples include a page that finishes with Alzheimer's disease references and a picture of an elderly person at a memory test, and a page that moves from cell energy to anti-ageing and longevity.

Restricted representations. References to serious diseases can only be used in advertising where the TGA has permitted or approved them.

Evidence type matters. A traditional indication needs traditional evidence. Presenting it with scientific claims shifts the evidence the TGA expects.

A review you can run this week

Open your best selling product page. Read it as someone who has never heard of your brand. Look at the name, hero image, headline, subheads, any education sections, reviews and the footer. Ask what that person would think the product is for. If the answer is wider than your listed indications, fix the page, not the label.

Then repeat for

Instagram captions and highlights, influencer briefs, marketplace listings, email flows and sales decks. Each is part of the same presentation.

This article is general information, not legal advice. Check the current Advertising Code and TGA guidance.

1. TGA, Making NAD, NAD+, NADH or NMN representations for listed medicines, 12 August 2026: tga.gov.au.
2. TGA, Applying the Advertising Code rules: prominently displayed or communicated information, 14 September 2026: tga.gov.au.
3. Therapeutic Goods Act 1989 (Cth), section 3 definitions of advertise and presentation.