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    Can Australian supplement brands use "immune support" on packaging?

    CompliGUARD reviews this compliance area against TGA · AHPRA · FSANZ · ACCC frameworks for Australian health brands — here's what the regulations say.

    CompliGUARD reviews supplement packaging claims like "immune support" against the TGA Advertising Code and permitted indications framework. Australian supplement brands can use "immune support" language only if the product is a Listed Medicine on the ARTG and the claim is within the permitted indications for the listed ingredients.

    The rule: Therapeutic Goods Advertising Code 2021, s.12, s.22 and Permitted Indications framework

    Under s.12 of the Therapeutic Goods Advertising Code 2021, advertisements for Listed Medicines must not include representations beyond what is permitted for the product's listed ingredients. The TGA publishes a Permitted Indications list for Listed Medicine ingredients. "Immune support" or "supports immune function" appears on this list for certain vitamins and minerals — but only at specified concentrations and only when the product holds an ARTG listing. For food products regulated under FSANZ, different rules apply and the Food Standards Code claim list must be consulted instead.

    What this means in practice

    • Check whether your product holds an AUST L number — if it does, TGA Advertising Code rules apply. If it does not, FSANZ food claim rules apply.
    • Look up your active ingredients in the TGA's Permitted Indications list. "Supports immune function" is permitted for vitamin C, zinc, and several other ingredients at specified concentrations.
    • Ensure the claim in your advertising exactly matches a permitted indication — do not paraphrase or expand it.
    • Never use "immune support" language alongside claims that the product treats, prevents, or cures a specific disease or condition.
    • Include mandatory statements on all advertising: AUST L number, sponsor name, and 'always read the label and follow the directions for use.'

    Common mistakes

    Mistake

    Using "boosts immunity" instead of "supports immune function"

    Problem

    "Boosts" implies a measurable therapeutic effect and is not a permitted indication — it implies the product elevates immune function beyond normal, which constitutes a therapeutic claim requiring evidence the product does not have.

    Fix

    Use the exact permitted indication language: "supports immune function" or "maintains immune system health" — match the wording in the Permitted Indications list precisely.

    Mistake

    Making immune claims on a food product without ARTG listing

    Problem

    A protein powder or functional food without an AUST L number is regulated under FSANZ, not TGA. Applying immune function language typically exceeds what FSANZ Standard 1.2.7 permits for food products.

    Fix

    Determine classification first using the TGA Food-Medicine Interface Guidance Tool. If the product is a food, check FSANZ Standard 1.2.7 for the approved general level health claims list.

    Mistake

    Omitting mandatory statements from social media posts

    Problem

    Social media posts advertising a Listed Medicine must include the AUST L number, sponsor name, and the 'always read the label' statement — even in short-form content. Omitting these is one of the most common infringement notice triggers.

    Fix

    Include mandatory statements in every post. For character-limited formats, the AUST number and 'always read the label' statement can appear in the caption body or as a text overlay.

    Compliant vs non-compliant example

    ❌ NON-COMPLIANT

    Using "boosts immunity" instead of "supports immune function"

    ✅ COMPLIANT

    Use the exact permitted indication language: "supports immune function" or "maintains immune system health" — match the wording in the Permitted Indications list precisely.

    The enforcement context

    In 2023–24, the TGA issued 147 infringement notices totalling $2.20 million, with immune and general health claims among the most frequently cited breach categories. Infringement notices for individuals are $10,350 per offence. The TGA uses automated monitoring tools to scan supplement brand websites and social media — content published years ago remains subject to current enforcement action.

    Before you publish, check it.

    CompliGUARD reviews supplement health claims against TGA Permitted Indications, the Advertising Code, and FSANZ Standards automatically.

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    Related questions

    Regulatory references

    • Therapeutic Goods Advertising Code 2021 (Cth), s.12
    • Therapeutic Goods Advertising Code 2021 (Cth), s.22 and Schedule 3
    • TGA Permitted Indications for Listed Medicines
    • Australia New Zealand Food Standards Code, Standard 1.2.7
    • TGA Food-Medicine Interface Guidance Tool