CompliGUARD compliance platform logoCompliGUARD
    TGA · AHPRA · FSANZ · ACCC

    Can I use customer testimonials in my supplement advertising in Australia?

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

    CompliGUARD checks supplement testimonials against the TGA Advertising Code before they go live. Testimonials are permitted in supplement advertising under the TGA Advertising Code, subject to strict conditions — they must not claim the product cured, treated, or prevented a disease, must reflect genuine consumer experience, and must not be misleading.

    The rule: Therapeutic Goods Advertising Code 2021, s.17–19

    Sections 17–19 of the Therapeutic Goods Advertising Code 2021 govern the use of testimonials in therapeutic goods advertising. A testimonial is permitted if it reflects the genuine opinion of the person giving it, is not misleading, does not include a claim that the product cured, treated, or prevented a disease, condition, ailment, or defect, and does not include a claim that the product will definitely work for other consumers. The Code also requires that if the testimonial is paid or incentivised, this is disclosed.

    What this means in practice

    • Screen all testimonials for language that implies the product cured, treated, or prevented a specific disease or condition — this language is prohibited regardless of whether the consumer genuinely experienced it.
    • Ensure testimonials reflect the genuine opinion of the person giving them — fabricated or substantially edited testimonials breach both the Advertising Code and the Australian Consumer Law.
    • Disclose any payment or incentive given to the person providing the testimonial.
    • Do not present a single testimonial as representative of typical consumer outcomes — include qualifying language where results are not typical.
    • For influencer testimonials: the brand is responsible for reviewing the content before it is posted if the brand commissioned or paid for it.

    Common mistakes

    Mistake

    Using testimonials that say "cured my [condition]" or "fixed my [problem]"

    Problem

    Claims of cure, treatment, or prevention of a disease are prohibited in testimonials under s.17(d) of the Advertising Code — the prohibition applies even when the testimonial is genuine and the consumer actually experienced that outcome.

    Fix

    Edit testimonials to describe the consumer's experience without disease or cure language: "I've felt so much better since starting this" rather than "this cured my iron deficiency."

    Mistake

    Reposting influencer testimonials without compliance review

    Problem

    Where a brand reposted, shared, or amplified influencer content promoting their product, the brand may be responsible for non-compliance in that content — even if the influencer wrote it independently.

    Fix

    Review all influencer content before the brand shares or reposts it. Retain a record of the version reviewed and the compliance outcome.

    Mistake

    Using before-and-after imagery alongside testimonials

    Problem

    Before-and-after imagery that implies a specific health transformation, when combined with a testimonial, compounds the misleading impression — the ACCC has taken action against this combination under the Australian Consumer Law even where the individual elements might have been permissible alone.

    Fix

    Avoid before-and-after formats for therapeutic good advertising. Use experiential language without visual implication of a specific health outcome.

    Compliant vs non-compliant example

    ❌ NON-COMPLIANT

    Using testimonials that say "cured my [condition]" or "fixed my [problem]"

    ✅ COMPLIANT

    Edit testimonials to describe the consumer's experience without disease or cure language: "I've felt so much better since starting this" rather than "this cured my iron deficiency."

    The enforcement context

    Testimonial-related breaches are among the most frequently cited in TGA infringement notices. In 2023–24, the TGA sent 4,806 removal requests — many targeting testimonial content on brand websites and social media that crossed into prohibited cure or treatment claims. For AHPRA-regulated practitioners, testimonials are prohibited entirely — a different and stricter rule applies to regulated health services.

    Before you publish, check it.

    CompliGUARD reviews testimonial content against TGA Advertising Code ss.17–19 and ACCC guidelines automatically.

    Start free review

    Related questions

    Regulatory references

    • Therapeutic Goods Advertising Code 2021 (Cth), s.17–19 (testimonials)
    • Australian Consumer Law (Competition and Consumer Act 2010, Schedule 2), s.18
    • ACCC Advertising and Selling Guide, July 2021