---
title: "Hair growth supplement manufacturer: the TGA rules"
description: "Hair growth supplement manufacturer guide for Australia: why a hair supplement is a TGA-listed medicine, the hair claims it can make, and our hair ranges."
url: https://takefridayoff.com/guides/hair-growth-supplement-development
updated: 2026-11-06
---
# Hair growth supplements: the rules and how to build one

https://takefridayoff.com/guides/hair-growth-supplement-development · Guide · last reviewed 2026-11-01

## In short
(https://takefridayoff.com/guides/hair-growth-supplement-development#in-short)

- A product taken by mouth and labelled or promoted for a cosmetic purpose, such as the look of hair, is declared a therapeutic good. It can't be sold as a food or a cosmetic, and it is usually a TGA-listed medicine.
- The Permissible Indications Determination has hair claims, such as "Maintain/support hair growth", "Maintain/support hair strength/thickness" and "Aid/assist/help/maintain healthy hair follicles", with scientific or traditional evidence.
- "Decrease/reduce hair loss/thinning" needs the label statement "If symptoms persist, talk to your health professional.", and the product can't imply or refer to serious conditions associated with alopecia.
- A matching serum can be a cosmetic, but a claim to promote hair growth will likely make a topical product a therapeutic good unless it is excluded.
- From our records: Pump Haircare's TGA-listed hair growth capsules, reordered since 2021 and upgraded with a full new listing package in 2026; and Vitable's hair capsule on a clinically studied Biota orientalis extract, with a matching cosmetic serum.

## Why a hair supplement is a medicine
(https://takefridayoff.com/guides/hair-growth-supplement-development#why-a-hair-supplement-is-a-medicine)

The Therapeutic Goods (Declared Goods) Order 2019 declares goods "labelled or promoted for cosmetic purposes" to be therapeutic goods "when used, advertised or presented for supply 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".

The cosmetic purpose and the oral route decide, not the format. A hair capsule, tablet, powder or liquid is covered alike. More in our [beauty supplements guide](https://takefridayoff.com/guides/beauty-supplements).

## The hair claims a listed medicine can make
(https://takefridayoff.com/guides/hair-growth-supplement-development#the-hair-claims-a-listed-medicine-can-make)

A listed medicine can only carry indications from the Therapeutic Goods (Permissible Indications) Determination (No. 1) 2025. The hair indications sit in Part 1, indications relating to general health or body parts:

| Indication | Evidence | Requirements |
| --- | --- | --- |
| Maintain/support hair growth | Scientific or traditional | None |
| Enhance/improve/promote/increase hair growth | Scientific or traditional | None |
| Maintain/support hair health | Scientific or traditional | None |
| Maintain/support hair strength/thickness | Scientific or traditional | None |
| Enhance/improve/promote/increase hair strength/thickness | Scientific or traditional | None |
| Aid/assist/help/maintain healthy hair follicles | 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 |

The sponsor holds the evidence for each indication the product carries ([permitted indications](https://takefridayoff.com/guides/permitted-indications)). The wording can be varied on the label, but the varied wording must not change the meaning or intent of the indication, imply a serious form of a disease, or imply that the medicine prevents or cures one. So a hair capsule can support hair growth, but it can't claim to treat or cure alopecia.

## Advertising a hair supplement
(https://takefridayoff.com/guides/hair-growth-supplement-development#advertising-a-hair-supplement)

The Therapeutic Goods Advertising Code applies to the product's ads, website and social media. An ad must not be inconsistent with the indications accepted for its ARTG entry, and it must not contain a picture or design that exaggerates the product's efficacy. Testimonials must be typical and verified, and paid testimonials aren't allowed, from brand ambassadors and social media influencers included ([TGA advertising](https://takefridayoff.com/guides/tga-advertising)). In its guidance on weight-management products, the TGA notes that before and after photos may indicate a claim.

## A matching serum or topical
(https://takefridayoff.com/guides/hair-growth-supplement-development#a-matching-serum-or-topical)

A hair range often pairs a capsule with something applied to the scalp. The topical has its own pathway. A cosmetic is decided by its claims, its ingredients and how it is used, and a claim to promote hair growth will likely make a product a therapeutic good unless it is excluded. So the serum's claims are written for the cosmetics pathway from the start, and the capsule carries the hair growth indications. Vitable's range works this way: a TGA-listed capsule and a matching serum on the cosmetics pathway ([skincare and topicals](https://takefridayoff.com/skincare)).

## Formulating and packing a hair supplement
(https://takefridayoff.com/guides/hair-growth-supplement-development#formulating-and-packing-a-hair-supplement)

- **Ingredients.** Every ingredient must be in the Permissible Ingredients Determination, used only in the roles it allows. Biotin, for example, can be an active ingredient or an excipient ([permissible ingredients](https://takefridayoff.com/guides/permissible-ingredients)).
- **Complex formulas.** Hair formulas often combine a botanical extract with vitamins and minerals. Vitable's capsule has more than 13 ingredients, including a clinically studied Biota orientalis extract, AnaGain™ under licence and Quatrefolic® active folate ([branded ingredients](https://takefridayoff.com/guides/branded-ingredients)).
- **Upgrading a formula.** Changing an active ingredient or its quantity makes a new medicine and a new listing. Pump Haircare's upgraded formula had a full new listing package and stability testing ([reformulating a supplement](https://takefridayoff.com/guides/reformulating-a-supplement)).
- **The pack.** A recycled pack is possible for a listed medicine. Vitable's capsule ships in a 100% recycled PET bottle, covered by the product's stability program like any other pack ([sustainable packaging](https://takefridayoff.com/guides/sustainable-supplement-packaging)).

## From our records
(https://takefridayoff.com/guides/hair-growth-supplement-development#from-our-records)

- [Pump Haircare](https://takefridayoff.com/work/pump-haircare-hair-supplement): a hairdresser-founded Australian hair care brand that moved into supplements. We built its TGA-listed hair growth capsules and managed manufacturing, imports and air freight for every order. Working together since 2021, a 2024 reorder ready ahead of schedule, and an upgraded formula with a full new listing package shipped in 2026, with another reorder in the pipeline.
- [Vitable](https://takefridayoff.com/work/vitable-hair-growth-range): a Sydney personalised-vitamin brand's hair range. A TGA-listed capsule with more than 13 ingredients in a 100% recycled PET bottle, and a matching topical serum on the cosmetics pathway. We formulated both, managed their manufacture and sourced the recycled bottles. Both delivered in 2024 and 2025.

## Frequently asked questions

**Is a hair growth supplement a medicine in Australia?**
Yes, when it is taken by mouth and labelled or promoted for a cosmetic purpose such as the look of hair. It is declared a therapeutic good and is usually a TGA-listed medicine.

**Can a hair supplement claim to stop hair loss?**
It can claim to "Decrease/reduce hair loss/thinning", with the label statement "If symptoms persist, talk to your health professional." It can't imply or refer to serious conditions associated with alopecia, or claim to cure them.

**Can a hair serum claim to grow hair?**
A claim to promote hair growth will likely make a topical product a therapeutic good unless it is excluded. A serum sold as a cosmetic keeps its claims cosmetic.

**Can a hair supplement and a serum be sold as one range?**
Yes. Vitable's range pairs a TGA-listed capsule with a serum on the cosmetics pathway, and we managed manufacturing for both.

## Case studies

- [Pump Haircare: A hair care brand that keeps coming back](https://takefridayoff.com/work/pump-haircare-hair-supplement): Working together since 2021
- [Vitable: A hair range in recycled packaging](https://takefridayoff.com/work/vitable-hair-growth-range): Both products delivered in 2024 and 2025.

## Sources

General information, checked against these sources between 23 October and 1 November 2026. It isn't advice on a particular product. Our work is from Take Friday Off's records.

- [Therapeutic Goods (Permissible Indications) Determination (No. 1) 2025](https://www.legislation.gov.au/F2025L00450/asmade/2025-04-02/text/original/epub/OEBPS/document_1/document_1.html), section 6 and Schedule 1, Part 1, Federal Register of Legislation (checked 1 November 2026)
- [Therapeutic Goods (Permissible Ingredients) Determination (No. 3) 2026](https://www.legislation.gov.au/F2026L01382), Schedule 1 (the biotin entry), Federal Register of Legislation (checked 1 November 2026)
- [Therapeutic Goods (Declared Goods) Order 2019](https://legislation.gov.au/F2019L01352/2023-03-01/2023-03-01/text/original/epub/OEBPS/document_1/document_1.html), section 5 and Schedule 1, Federal Register of Legislation, and [Complementary medicine interface issues](https://www.tga.gov.au/node/452720), Therapeutic Goods Administration, as set out in our [beauty supplements guide](https://takefridayoff.com/guides/beauty-supplements)
- [Therapeutic Goods (Therapeutic Goods Advertising Code) Instrument 2021](https://www.legislation.gov.au/F2021L01661/latest), and [Testimonials and endorsements in advertising](https://tga.gov.au/node/491816), Therapeutic Goods Administration, as set out in our [beauty supplements guide](https://takefridayoff.com/guides/beauty-supplements)
- [Cosmetics and therapeutics](https://www.industrialchemicals.gov.au/cosmetics-and-soap/cosmetics-and-therapeutics), Australian Industrial Chemicals Introduction Scheme, as set out in our [skincare page](https://takefridayoff.com/skincare)