11 August 2026
Therapeutic Goods Administration Department of Health, Disability and Ageing
Submission by the ATMS
Consultation on Changes to the Permissible Indications Determination
Background
The Australian Traditional Medicine Society (ATMS) is the leading professional association for complementary medicine practitioners in Australia. ATMS members include a large number of professionally accredited naturopaths, nutritionists and Western medical herbalists- practitioner who have significant expertise in the prescription of herbal and nutritional medicines, and the guidance of those who use them.
Responses to matters raised by the Consultation document
Because they have little relevance to the normal activities of its accredited members, the ATMS has no comment to make in regard to the Consultation questions associated with Issues 1, 3, 4 and 5. As a general statement, the ATMS supports any reforms that lead to an improved efficiency in therapeutic goods use and a minimisation of risk from therapeutic goods.
The ATMS does have concerns regarding Issue 2- Inconsistent/incorrect requirements for indications relating to the thyroid.
The ATMS understands and accepts that indications for listed medicines may not refer to the treatment of a serious form of a disease, ailment, defect or injury, or refer to the prevention or cure of any disease, ailment, defect or injury, and that thyroid diseases may form part of this category. It also understands the need to address the inconsistency in requirements between thyroid indications. However, we disagree with the proposal to include the label statement, “If you have pre-existing thyroid conditions, seek advice from your medical practitioner before taking this medicine.”
While we agree with the intention here, we would like to suggest that this statement be modified to read, “If you have pre-existing thyroid conditions, seek advice from your health professional (or words to that effect) before taking this medicine.” There are several reasons for suggesting this.
- The bulk of the ARTG listed medicines that carry thyroid indications are complementary medicines that are composed of nutrients such as B group vitamins, selenium, zinc and herbs such as Fucus vesiculosus (Kelp/Bladderwrack). Most medical practitioners have not been trained in the use of, or the pharmacological activity of, these Nor do they commonly have experience in assessing or managing a consumer’s physiological response to these ingredients. Other healthcare providers such as naturopaths working in pharmacies or health food stores and quite frequently, pharmacists who have post-graduate training and/or experience in this area, are far better suited to advise consumers on these medicines. Confining advisors to medical practitioners would exclude these other expert healthcare practitioners from being able to advise on these medicines.
- Listed complementary medicines are usually sold in health food stores and pharmacies- locations where medical practitioners are not normally found. To restrict the advisor group for these products to medical practitioners would result in consumers not being able to legally seek advice on the use of these products at the point of purchase and would need to consult a medical practitioner. Most consumers would be loathe to do this and the likely outcome would be consumers using these products without appropriate advice, or consumers seeking to procure these products online- a potentially unregulated environment where risk from inappropriate use is increased.
- The majority of listed complementary medicines sold in Australia carry the label statement, “If symptoms persist, talk to your health professional” or words to that effect. The proposed change to this statement would create a labelling inconsistency that’s not in the interest of consumers, industry, or regulators.
