Beauty supplements in Australia: why a skin, hair or nail supplement is a medicine

Why it's a medicine

The Therapeutic Goods (Declared Goods) Order 2019 declares "goods that are labelled or promoted for cosmetic purposes" to be therapeutic goods "when used, advertised or presented for supply for oral consumption". The TGA says the Order commenced on 22 October 2019. It replaced earlier orders, among them a 1999 order that declared products labelled or promoted for cosmetic purposes to be therapeutic goods when promoted for oral consumption.

In the TGA's words, oral supplements "labelled or promoted for cosmetic purposes, such as to improve the appearance of skin, hair and nails, are legally declared to be therapeutic goods". "These products cannot be regulated as foods or cosmetics", and they "are usually included in the ARTG as low risk listed medicines and can only use claims included in the Therapeutic Goods (Permissible Indications) Determination." Food law agrees: in the FSANZ Act, "food does not include a therapeutic good".

For this declaration, the cosmetic purpose and the oral route decide, not the format. The TGA's guidance names tablets, powders and liquids among the ways a product is taken by mouth, and the declaration covers any of them presented for a cosmetic purpose. Without that purpose, the TGA says health claims don't automatically make a product a therapeutic good, "Nor does the fact that the product comes in capsules or powders, or is labelled as a 'dietary supplement'". (Some other declarations in the same Order do turn on the dosage form.) Our food pathway covers where the line falls for products without a cosmetic purpose.

What a beauty supplement can claim

As a listed medicine, a beauty supplement can only use the indications in the Therapeutic Goods (Permissible Indications) Determination (No. 1) 2025, each backed by the type of evidence it names and meeting any requirement it sets. Among them:

Indication	Evidence	Requirements
Maintain/support hair health	Scientific or traditional	None
Enhance/improve/promote/increase hair growth	Scientific or traditional	None
Enhance/improve/promote/increase hair strength/thickness	Scientific or traditional	None
Decrease/reduce hair loss/thinning	Scientific or traditional	The label statement "If symptoms persist, talk to your health professional.", and a presentation that doesn't imply or refer to serious conditions associated with alopecia
Maintain/support nail health/strength/thickness	Scientific or traditional	None
Decrease/reduce nail brittleness/splitting/chipping	Scientific or traditional	The same label statement
Maintain/support collagen formation	Scientific only	None
Helps enhance/promote collagen formation	Scientific only	None

The Determination also has a part of indications relating to skin. The wording can be varied, but it must not "change the meaning or intent of the indication", and an indication based on traditional evidence must carry a traditional context qualifier on the label. More in our claims and indications guide.

Claims a beauty supplement can't make

• Anti-ageing. The TGA says a "skin anti-ageing" claim "is not permitted for non-sunscreen medicines that are available for self-selection without prior evaluation by the TGA".
• Skin whitening. The TGA has found skin whitening claims "not permitted for listed medicines without prior evaluation or approval from the TGA", and has stopped listed medicines that made them.
• Anything beyond the permitted list. A claim that goes further needs the TGA to assess it first, as an assessed listed medicine or a registered one.

Collagen and other ingredients

Every ingredient in a listed medicine must be in the Therapeutic Goods (Permissible Ingredients) Determination, used only for the purposes it allows: as an active ingredient, an excipient or both, within any limits it sets. For three ingredients common in beauty supplements, the Determination says:

• Biotin can be an active ingredient or an excipient.
• Hyaluronic acid itself is "Only for use as an excipient in topical medicines for dermal application". Its sodium salt, sodium hyaluronate, has an entry of its own, which a 2021 change opened to use as an active ingredient.
• Ingredients of animal origin, such as collagen: their safety must have been assessed against, and comply with, the principles and requirements of European Pharmacopoeia general monograph 1483. The ARTG includes listed medicines with hydrolysed collagen as an ingredient, such as ARTG entry 346618.

An ingredient that isn't in the Determination, or one wanted in a role it doesn't allow, needs an application to the TGA first: see our new ingredients guide.

Advertising a beauty supplement

The Therapeutic Goods Advertising Code applies to its ads, its website and its social media, as for any medicine:

• Within the listing. An ad "must not be inconsistent with any indication or intended purpose accepted" for the medicine's ARTG entry, and must be accurate, balanced and substantiated before it is published.
• Images count. An ad must not contain a "pictorial representation or design" that exaggerates the product's efficacy or performance. In its guidance on weight-management products, the TGA notes that "Before and after photos may indicate a claim in the eyes of the consumer".
• Testimonials. A testimonial's health benefit must be typical of what the product gives, it can't come from anyone engaged in the product's production, marketing or supply, and the advertiser must verify it. Paid testimonials aren't allowed, and the TGA says "This includes brand ambassadors and social media influencers."

More in our advertising guide.

The TGA's recent cases

The TGA's compliance reports and safety alerts show how it treats beauty products:

• Skin whitening. In September 2023, "Liver Detox Max Skin White & Light Plus" (Fairy Wings Pty Ltd): its claims were "not permitted for listed medicines without prior evaluation or approval from the TGA", and the medicine was no longer permitted to be supplied. In September 2024, the TGA itself cancelled "Luxxe White Enhanced Glutathione" (FR International Australia Pty Ltd), whose name implied skin whitening, and glutathione the product didn't contain.
• Anti-ageing. In June 2024, "Ultra Nature Skin Anti-Ageing + Energy" (Selima Pharmaceuticals): its name implied a skin anti-ageing benefit, which isn't permitted, and the sponsor cancelled the listing.
• Safety. The TGA has warned consumers that "Natures Valley Collagen Builder" tablets, which it had not assessed, contain "199.3 milligrams per tablet of an undeclared medicine called sildenafil".

Taken by mouth, or put on the skin

The declaration is about what is swallowed. A cream or serum for the skin that makes only cosmetic claims, and has no ingredient in a schedule of the Poisons Standard, is generally regulated as a cosmetic rather than a therapeutic good. So a brand selling a hair capsule and a hair serum sells two products under two sets of rules, as Vitable's hair range does. More on the cosmetic side in our skincare page.

Changes in 2026

From 1 July to 12 August 2026 the TGA consulted on changes to the Permissible Indications Determination, among them changing "Helps reduce occurrence of symptoms of eczema/dermatitis" to "Helps reduce occurrence of symptoms of mild eczema/dermatitis". No outcome had been published by 23 October 2026. Its consultation on improving the Advertising Code ran from 9 July to 3 September 2026: our advertising guide covers it.

Where we come in

We have taken skin and hair supplements to market for Pump Haircare (hair growth capsules, a client since 2021), Vitable (a hair capsule and matching serum), an Australian skincare brand (a probiotic skin supplement, from design to production order in 12 weeks) and the skin-check service Your Skin Scan (a nicotinamide tablet). We check the claims at the brief, against the permitted indications, so the formula, the evidence and the label are built around claims the product can make. More on skincare and cosmetics, or book a call.