What should a naturopath check before posting advertising in Australia?
CompliGUARD reviews this compliance area against TGA · AHPRA · FSANZ · ACCC frameworks for Australian health brands — here's what the regulations say.
Naturopaths promoting therapeutic goods or making health claims must check advertising against the TGA Advertising Code 2021, FSANZ Standard 1.2.7, and the Australian Consumer Law before publishing. CompliGUARD automates all three checks in a single review.
The rule: Three frameworks, one piece of content, TGA Advertising Code 2021 ss.4 and 18; FSANZ Standard 1.2.7; ACL s.18
Most naturopath advertising touches all three simultaneously. TGA Advertising Code 2021, ss.4 and 18 — applies to any therapeutic good you promote, recommend, or describe. This includes supplements, herbal remedies, and any ARTG-listed product. Claims must match the product's ARTG indication. Unsubstantiated therapeutic representations — including implying a product treats, cures, or prevents a disease — are prohibited under s.4. FSANZ Food Standards Code, Standard 1.2.7 — applies when you make nutrition or health statements about food products including herbal teas, food-classified nutritional powders, and whole-food supplements not listed on the ARTG. General level health claims require pre-approved wording from the schedule. High level health claims require an ARTG authorisation or a food-health claim approval. Australian Consumer Law, s.18 — applies to all consumer-facing advertising regardless of what is being promoted. No misleading claims, no implied guarantees of outcomes, no false impression about the nature or effect of your service or products.
What this means in practice
- If you promote a supplement or herbal remedy: Confirm the product's ARTG listing and check its permitted indication. The claim on your advertising must correspond to an approved indication for that specific product — not just what the manufacturer says or what is common practice in your profession.
- If you promote food-classified herbal or nutritional products: FSANZ Standard 1.2.7 applies. The distinction between a therapeutic good and a food is determined by the TGA's Food-Medicine Interface Guidance Tool — not by the product's packaging category. Check before you publish.
- For testimonials from clients: Permitted under Australian Consumer Law. However, under TGA Advertising Code 2021 s.18, testimonials for therapeutic goods cannot imply a product treats, prevents, or cures a disease. The advertiser is responsible — not the client who wrote the testimonial.
- For before/after content, case studies, or outcomes claims: The TGA and the ACCC both assess the overall impression an advertisement creates on a reasonable consumer — not just the literal words. A transformation image without a claim can still constitute a misleading representation.
- For email newsletters, social media, and paid ads: Each piece is assessed independently. Sharing a link to a product page that contains non-compliant claims may also constitute advertising that claim.
A pre-publication workflow for naturopaths
- Identify what you're advertising — a health service, a therapeutic product, a food product, or a combination.
- If a product: confirm its ARTG status using the TGA's ARTG search. Check the product's permitted indications.
- Map every claim in your content to its applicable framework — TGA Advertising Code, FSANZ Standard 1.2.7, or Australian Consumer Law.
- Check that testimonials and client quotes do not contain prohibited therapeutic representations under TGA Advertising Code 2021 s.18.
- Review the overall impression: would a reasonable consumer draw a misleading conclusion from the advertisement as a whole?
- Run the content through CompliGUARD for an automated compliance review against the TGA Advertising Code 2021, FSANZ Standard 1.2.7, and the Australian Consumer Law — before it goes live.
- For higher-risk content involving disease claims, clinical outcomes, or before/after imagery, obtain regulatory or legal review before publishing.
Common mistakes
Using "heals", "cures", "reverses", or "treats" for any ARTG-listed product
These are prohibited therapeutic representations under TGA Advertising Code 2021 s.4, regardless of how commonly they appear in natural therapy practice.
The TGA's enforcement priority list consistently targets this language in the complementary medicine and natural therapy sector.
Sharing manufacturer testimonials without checking the claim
Under TGA Advertising Code 2021 s.18, the advertiser is responsible for the content of testimonials they publish, not the manufacturer who provided them.
If the testimonial implies a therapeutic good can treat a disease, you are responsible for that claim.
Treating herbal food products and therapeutic goods as the same
ARTG-listed products and food-classified products operate under different regulatory frameworks. A herbal tea that makes a health claim may trigger FSANZ Standard 1.2.7; the same product reformulated as a supplement may trigger the TGA Advertising Code.
The rules are different and both apply.
Compliant vs non-compliant example
❌ NON-COMPLIANT
Using "heals", "cures", "reverses", or "treats" for any ARTG-listed product
✅ COMPLIANT
The TGA's enforcement priority list consistently targets this language in the complementary medicine and natural therapy sector.
The enforcement context
In 2023–24, the TGA issued 4,806 removal requests and 147 infringement notices totalling $2.20 million — an average of $19,800 per notice. Immunity, mental wellbeing, digestive health, and weight management are among the TGA's highest-priority enforcement categories. These are the same claim types that appear most frequently in naturopath advertising. The ACCC actively investigates misleading health claims under Australian Consumer Law s.18 and pursues penalties for false representations about therapeutic goods and services. Naturopath advertising accounts for a consistent share of TGA and ACCC complaints each year. The risk is not theoretical.
Before you publish, check it.
CompliGUARD reviews naturopath advertising against the TGA Advertising Code 2021, FSANZ Standard 1.2.7, and the Australian Consumer Law automatically — in one review, before your content goes live.
Start free reviewRelated questions
Regulatory references
- Therapeutic Goods Advertising Code 2021, ss.4, 10, 18 (therapeutic representations, mandatory statements, testimonials)
- FSANZ Food Standards Code, Standard 1.2.7 (Nutrition, Health and Related Claims)
- Australian Consumer Law (Competition and Consumer Act 2010, Schedule 2), ss.18, 29, 33 (misleading conduct, false representations, misleading conduct as to nature of goods)
- Therapeutic Goods Act 1989 (Cth), s.42DL (advertising offences)
CompliGUARD provides compliance insights based on TGA, FSANZ, ACCC and AHPRA guidance current at the time of review. The Therapeutic Goods Advertising Code is under formal review by the TGA (2025–26). This content does not constitute legal advice.