Transitioning to 2018 Therapeutic Goods Advertising Code.
An answer (of sorts)!
It was always an ambitious ask to have the 2018 Therapeutic Goods Advertising Code be available for 1st July.
And if that were possible, how would we be expected to manage the transition period between the two codes. How much time would advertisers have to update content to ensure it complies with the new Code?
Well now there is some clarity. The 2018 TGAC will come into effect on 1st July. Congrats to the TGA team for achieving this mammoth ask.
The commencement date of the Code will be delayed for 6 months ie it will be enforced from 1st January 2019. During this time advertisers are encouraged to become familiar with the new Code and make use of the training materials the TGA has made available. The content is expected to be developed over the weeks and months and The Advertising Compliance branch is encouraging advertisers or interested parties to contact them directly with specific requirements.
To assist with the transition, a cross-reference table will be made available to detail where changes have been made between the draft and final Code (once it has been released). These changes have been made following responses received during the public consultation period.
I have 4 points here that are a good starting place for key changes :
- The new Code will clarify which mandatory statements are required if the physical product is not available for examination at the time of purchase. This should adequately cover online selling of therapeutic goods to ensure customers are adequately informed prior to purchase.
- A section will be added to highlight that when using a comparison in advertising, it must not imply the comparator is harmful or ineffectual. This is consistent with the current Code.
- There was recognition that children may be exposed to advertising for therapeutic goods, however an advertisement should not be directed primarily to them. The wording has been adjusted to reflect this point. Note that child-friendly labels will still be permitted.
- The section regarding Allergies and necessary warnings has (thankfully!) been removed.
That's all for today but I will be posting again next week with information about pre-approved advertisements and to which Code they should be created to abide by.
Until then, keep honest!