Can Australian food products use the word 'supports' in health claims?
CompliGUARD reviews this compliance area against TGA · AHPRA · FSANZ · ACCC frameworks for Australian health brands — here's what the regulations say.
CompliGUARD reviews "supports" health-claim language on food products against the FSANZ Food Standards Code. The word 'supports' can be used in health claims on Australian food products, but only if the specific claim is on the FSANZ pre-approved general level health claims list or has been self-substantiated — 'supports' is not a magic word that makes any health claim automatically permissible.
The rule: Australia New Zealand Food Standards Code, Standard 1.2.7, s.13 (general level health claims)
Under Standard 1.2.7, general level health claims link a food or nutrient to a health effect that is not a disease. The pre-approved list includes claims using language such as 'supports', 'maintains', 'helps', and 'contributes to' — but only for specific nutrient-health relationships that have been assessed and approved. The word 'supports' does not authorise a claim on its own. A claim like 'supports immune health' on a food product must correspond to an approved claim on the general level health claims list. If the specific nutrient-health relationship is not on the list, 'supports' language does not make it compliant.
What this means in practice
- Before using 'supports' or 'maintains' in a health claim on a food product, check whether the specific nutrient-health relationship appears on the FSANZ pre-approved general level health claims list.
- The claim must match the approved claim in substance — rephrasing an approved claim using 'supports' does not make an unapproved claim permissible.
- If the nutrient-health relationship is not on the approved list, complete the FSANZ self-substantiation process before using the claim.
- For products that are Listed Medicines (AUST L), TGA Permitted Indications language applies instead — check which framework governs your product before selecting claim language.
- The ACCC's misleading conduct rules apply regardless of claim language — a technically FSANZ-compliant 'supports' claim can still be misleading if the product does not deliver the implied benefit.
Common mistakes
Assuming 'supports' language is always safe for food products
'Supports immune function' on a food product is only permitted if the specific ingredient-claim relationship is on the FSANZ pre-approved list. Many brands assume softening language like 'supports' creates a safe harbour — it does not.
Check the FSANZ pre-approved general level health claims list for the specific nutrient and health relationship. If it is not listed, the claim is not permitted regardless of the language used.
Using 'supports' claims on food products that contain ingredients at therapeutic doses
Where a food product contains an ingredient at a concentration that would typically indicate therapeutic use, the TGA may classify the product as a therapeutic good regardless of how the claim is framed. 'Supports' language does not prevent TGA classification if the ingredient concentration and marketing position indicate therapeutic intent.
Use the TGA Food-Medicine Interface Guidance Tool to confirm product classification before applying FSANZ claim language. If classification is unclear, seek regulatory advice.
Applying TGA Permitted Indications language to FSANZ-regulated food products
TGA Permitted Indications are approved for Listed Medicines — not for food products. A claim permitted under TGA for a Listed Medicine is not automatically permitted under FSANZ for a food product, even if the language is identical.
Apply the correct framework's claim list to each product based on its classification. Do not cross-reference frameworks as if the permitted claims are equivalent.
Compliant vs non-compliant example
❌ NON-COMPLIANT
Assuming 'supports' language is always safe for food products
✅ COMPLIANT
Check the FSANZ pre-approved general level health claims list for the specific nutrient and health relationship. If it is not listed, the claim is not permitted regardless of the language used.
The enforcement context
FSANZ and state food authorities monitor health claim compliance on food products. The ACCC has separately taken action against food businesses using 'supports' and 'helps' language that implied health benefits the product could not substantiate. Both enforcement pathways can apply simultaneously where a health claim is both outside the FSANZ approved list and misleading under the Australian Consumer Law.
Before you publish, check it.
CompliGUARD checks 'supports' and related health claim language on food products against the FSANZ pre-approved general level health claims list.
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Regulatory references
- Australia New Zealand Food Standards Code, Standard 1.2.7, s.13 (general level health claims)
- Australia New Zealand Food Standards Code, Standard 1.2.7, Schedule 2
- FSANZ Pre-Approved General Level Health Claims List
- Australian Consumer Law (Competition and Consumer Act 2010, Schedule 2), s.18