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Commercial Health Product Marketing

At the Pharmacy

More than 2 billion dollars of over the counter sales of medicines were reported in Australia during 2015. Since then, sales in pharmacies and supermarkets in Australia have increased to $4.5 billion in 2021. With Australia importing more than 90% of medicines that Australians consume, the pandemic effected sales with interruptions in supply, COVID-19 lockdowns, illicit drug trafficking and panic buying. 1 2 3


The Australian Register of Therapeutic Goods reported approximately 158, 500 therapeutic goods registered in January 2023. Of the 34, 000 registered as medicines, 800 medicines were reported in shortage by the Australian Active Shortage Report. The 300% rise in shortage has left Australian consumers vulnerable to waiting periods of offshore critically prescribed medicines. 4 5 6 


A study surveying healthcare professionals indicated most health care professionals preferred the adapted changes by pharmaceutical  companies promoting products with self-directed digital content and virtual interactions. The shift to 65% of meetings being held virtually with sales representative has improved education resources for patients and solutions to keeping stock of therapies. 7


Alternative unapproved overseas generic medicines have been a replacement to manage unavailable products in the case of shortages. Many are expensive, suboptimal and short supplied drugs. Patients have become more interested in being part of the decision making when choosing alternative therapies. 8


Consumer Product Information on Prescribed Medicines and Devices

Direct advertising of prescription medicines and devices to consumers is not permitted in Australia. Information for prescription medicines and devices can only be on labels, packaging and materials in packaging. Alternative generic medicines have been subject to the same advertising requirements.

Advertising Over the Counter Medicines and Devices

Over the counter medicines or devices sold through pharmacies and supermarkets are regulated in Australia with the Therapeutic Goods Advertising Code. Channels for advertising are radio, TV, websites, apps, social media, medical journals, magazines, catalogues, videos and direct marketing. Information about the product, warnings for use and advice to seek assistance must be communicated.


Health providers keep informed about advertising strategies engaging consumers. Direct-to-consumer advertising is most supported when information reinforces the provider-client relationship and public health messages. Compliance in advertising rules empower patients using education to seek medical attention to diagnose conditions, make assertive decisions in choice of treatment, be active in continuous self-monitoring to detect adverse reactions and value compliance. 9

Compliance Regulations

Pharmaceutical organisations and commercial businesses aim to drive profitable action with information provided to consumers. Therapeutic products provided to the public need to comply with the Therapeutic Goods Advertising Code 2021 to ensure they are responsible and not misleading. In 2021, an approximate 2000 reports of alleged non-compliance were received by the Therapeutic Goods Advertising Administration.  10


Advertising of products needs to be compliant with:

  • Therapeutic Goods (Therapeutic Goods Advertising Code) Instrument 2022

  • Australian Consumer Law

  • National Health Practitioner Law

  • Poisons legislation

  • FreeTV Australia's Commercial Advice (TV and Radio)

  • Industry self-regulatory codes (Medicines Australia Code of Conduct, Australian Self Medication Industry Code of Practice, Medical Technology Association of Australia Code of Practice and IVD Australia Code of Conduct). 11


Intensive research by copywriters can balance authentic representation of the product and comparisons with competitors. Medicines Code has monitored and enforced legal action to impose sanctions against companies breaching representation of medicines during the last four years with false claims; using emotive language for clinical efficacy, lacking detail with inadequate context in supporting evidence, inconsistent key clinical trial data, unsubstantiated body of evidence, unapproved final consent of a healthcare professional in a video presentation, failure to disclose the market researcher, incorrect comparisons between the products, implying a dosing equivalence that was inaccurate and misrepresenting data that the products may be interchangeable. 12

Effective and Compliant Copywriting

Copywriters can write simple or complex information. Support your marketing campaign with legal knowledge into important considerations about accessibility for all target audiences, requirements for different channels, focus features in documents, substantiated evidence before advertising, considerations in advertising to children, authorised samples and campaigns integrating with safe public health priorities.


Follow guidelines with essential information for advertising such as mandatory statements, warnings, correct use of words, accurate claims of effectiveness, testimonials and endorsements, AUST number, consistency with labels, safe instructions, comparisons, simple scientific explanations and disclosure of financial sponsors. Produce work in accordance with specific requirements for writing instructions for actions, mandatory choice of words, SEO, value, authentic claims in taglines, size of font, date of review, job number, personal injury references to adverse reactions, company details and references to graphs.  13


Use your brands foundations, writing principles, sales copywriting strategies and personas for the buyer’s journey. Focus on launching or advertising your product with patient centric writing. Reach the largest scope of physicians, pharmacists and consumers.


1. Statistica. (n.d.). Sales of over-the-counter medicines in Australia from 2011 to 2015.

2. Global Data. (2022, March 31). Australia over-the-counter (OTC) healthcare market size by categories, distribution channel, market share and forecast, 2021-2026.,at%20%244.5%20billion%20in%202021.

3. Second Line of Defence Info. (2022, February 16). Australia’s Medicine Supply: A Case Study in Security and Resilience?

4. Therapeutic Goods Administration. (n.d.). Australian Register of Therapeutic Goods (ARTG). Australian Government, Department of Health and Aged Care. https://

5. Therapeutic Goods Administration. (n.d.). Medicine shortage reports database. Australian Government, Department of Health and Aged Care.


6. Sheshtyn, P. (2021, August 24). Australia 'vulnerable' to meds shortages. Australian Journal of Pharmacy.

7. Accenture. (2020, August 10). Pharma Companies Have Improved How They Engage with Healthcare Providers During COVID-19, Finds New Research from Accenture.

8. Orlovich, D. S,, Mincer, S. L,, & Domino, K. B. (2020). Analgesic medication shortages: Inform our patients via a shared decision-making process. Anesthesia & Analgesia,  130(1),:265-270. doi: 10.1213/ANE.0000000000004514.


9. Ventola, C. L. (2011). Direct-to-consumer pharmaceutical advertising: therapeutic or toxic? Physical Therapy, 36(10), 669-84. .


10. Therapeutic Goods Administration. (2022). Therapeutic Goods Advertising Compliance Annual Report 2021-22. Australian Government, Department of Health and Aged Care, commonwealth of Australia.

11. Therapeutic Goods Administration. (2020, October 28). The advertising regulatory framework. Australian Government, Department of Health and Aged Care,

12. Medicines Australia. (n.d.). Monitoring compliance.

13. Medicines Australia (2016). Code of Conduct Guidelines (Version 2).

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