The Therapeutic Goods Advertising Code (No.2) 2018 (the Code) is the compliance standard that prescribes the minimum requirements for the lawful advertising of therapeutic goods to the public in Australia. It is an important instrument for a range of stakeholders including advertisers, manufacturers, suppliers and retailers; relevant industry associations; health professionals and peak bodies; and consumers and consumer representative groups. With the potential for serious consequences for non-compliance, it is important that the Code is contemporary and clear.

In this consultation the Therapeutic Goods Administration (TGA) was seeking feedback on options to improve the Code. The proposed improvements were aimed at increasing advertisers’ understanding of the requirements of the Code, ensuring provisions work as intended, and improving advertising compliance. The proposed improvements considered the need to minimise unnecessary compliance costs while continuing to ensure that advertising does not contribute to any unsafe or improper use of advertised products.

The Consumers Health Forum of Australia (CHF) is the national peak body representing the interests of Australian healthcare consumers and those with an interest in health consumer affairs, including health-based research. We have over 260 members reflecting a broad spectrum of organisations including state-based consumer peaks, condition-specific groups, volunteer patient groups, professional associations, Primary Health Networks (PHNs) and the research community.

We work in collaboration with our members, national partners and research collaborators to influence policy, programs and services to ensure they are in the consumer and community interest. This includes our role on the TGA Advertising Consultative Council (TGACC) as consumer representatives.

CHF is pleased to make this submission in response to this TGA Consultation.