TGA · AHPRA · FSANZ · ACCC

What are the advertising rules for naturopaths in Australia?

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

CompliGUARD reviews naturopath advertising against the TGA Advertising Code and Australian Consumer Law. Naturopaths are not currently registered under AHPRA, meaning AHPRA's advertising prohibitions do not directly apply — however, naturopaths advertising therapeutic goods must comply with the TGA Advertising Code, and all health claims are subject to the Australian Consumer Law prohibition on misleading conduct.

The rule: Therapeutic Goods Advertising Code 2021 / Australian Consumer Law, TGA Advertising Code 2021; ACL s.18 (Competition and Consumer Act 2010)

Naturopathy is not a nationally registered profession under the Health Practitioner Regulation National Law — naturopaths are not registered with AHPRA and are not subject to AHPRA's advertising guidelines. However, this does not mean naturopath advertising is unregulated. Where a naturopath sells, recommends, or advertises therapeutic goods (Listed or Registered Medicines), TGA Advertising Code obligations apply. All naturopath advertising is subject to the Australian Consumer Law's prohibition on misleading or deceptive conduct. And where naturopaths are members of professional associations that have their own advertising standards (such as NHAA or ATMS), those standards may impose additional obligations.

What this means in practice

Naturopaths advertising or recommending Listed Medicines (supplements, herbal products) must comply with the TGA Advertising Code — including permitted indications, testimonial rules, and mandatory statements.
Do not make claims that products or services treat, cure, or prevent specific diseases — this is misleading conduct under s.18 of the Australian Consumer Law regardless of whether you are AHPRA-registered.
Check your professional association's advertising standards — NHAA, ATMS, and other associations publish their own guidelines that members are required to follow.
Maintain records of the basis for any health claims you make — if a claim is challenged, you will need to demonstrate it was not misleading.
If recommending or selling products that are Listed Medicines, the TGA's rules about advertising those products apply to you as the advertiser.

Common mistakes

Mistake

Assuming 'not AHPRA regulated' means advertising is unrestricted

Problem

While AHPRA's specific advertising prohibitions do not apply to unregistered practitioners, the Australian Consumer Law applies to all businesses and prohibits misleading health claims regardless of professional registration status.

Fix

Apply the same care to advertising claims that a registered practitioner would — the consequence of a misleading claim may be an ACCC investigation rather than an AHPRA complaint, but the outcome is enforcement action either way.

Mistake

Making clinical outcome claims without substantiation

Problem

Claims that naturopathic treatment can resolve specific health conditions — without evidence to substantiate them — constitute misleading conduct under the Australian Consumer Law, regardless of whether they are technically true for some patients.

Fix

Frame services as an approach or modality rather than a guaranteed outcome. Where evidence exists for a claim, retain the evidence in case it is challenged.

Compliant vs non-compliant example

❌ NON-COMPLIANT

Assuming 'not AHPRA regulated' means advertising is unrestricted

✅ COMPLIANT

The enforcement context

The ACCC has taken action against complementary health practitioners and businesses for misleading health claims under the Australian Consumer Law. The TGA has also pursued naturopaths and natural health businesses for advertising therapeutic goods in breach of the Advertising Code — including social media content promoting herbal products with unapproved therapeutic claims.

Before you publish, check it.

CompliGUARD reviews naturopath and natural health advertising against TGA Advertising Code and ACCC ACL frameworks.

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Regulatory references

Therapeutic Goods Advertising Code 2021 (Cth)
Australian Consumer Law (Competition and Consumer Act 2010, Schedule 2), s.18
ACCC Advertising and Selling Guide, July 2021
NHAA Advertising Standards (where applicable to NHAA members)
ATMS Code of Conduct (where applicable to ATMS members)