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roddy000, post: 183175 wrote:
Thanks Cat. One issue is getting clear directions to ensure that the product is not actually a therapeutic product by definition. TGA has given us the written definition but it is so broad that it doesn’t seem to help. We don’t believe this is a medical/therapeutic product. They wouldn’t comment. I assume that if we don’t believe this is a therapeutic product and we make no claims to that effect, we should be ok. But – we want to be sure.

Hi Roddy,

That’s is on purpose I believe with having it all so broad. Now, the other thing they take into account is not just what you say about the product but how it is displayed, the website, packaging etc. because when looking at the whole picture, it may be considered a therapeutic product and need to be listed. So this needs to have careful consideration.
With them having it broad it allows more to fall into the net of needing to have products listed with TGA. If a product is then listed with TGA it needs to be manufactured by somewhere that has a GMP license so it all starts to become a little too hard for a lot of people. And a lot of people do have great products that do work, but because of the loopholes they often cannot go down the TGA road which puts them at a disadvantage.
Five years ago they told me I could mention this, this and this and now they are saying those things can’t be mentioned because they have changed their guidelines! So just imagine the expense in 1. the time invested into the product
2. the costs involved with label design, printing plates getting made, thousands of labels being printed, the flyers, posters, T-banners, artwork for advertising, adverts themselves and so on….and then having to pull everything from the shelves and redesign the whole lot and go to all of those expenses once again, just because they have now broadened the net.

You just need to be cautious about how you word things. For instance instead of saying ‘this product alleviates back pain’ you need to perhaps say ‘this product may help by relaxing.’ I’m not saying that is exactly how you would need to say it for your particular product but if you want any help with it PM me and I will give you my details so we can talk further on it and I may be able to assist you with it.

All the best!
Cat