Pet supplements in Australia: APVMA registration or pet food?

Medicine or food: where the line falls for animals

The Agricultural and Veterinary Chemicals Code (the Agvet Code) defines a veterinary chemical product by what it is for. It is a substance or mixture "represented as being suitable for, or is manufactured, supplied or used for, administration or application to an animal by any means, or consumption by an animal", as a way of, among other things, "preventing, diagnosing, curing or alleviating a disease or condition in the animal", or modifying its physiology to alter its natural development, productivity, quality or reproductive capacity, or to make it more manageable. In the Code, "claim includes any statement".

So the APVMA looks at two things: in its words, "both the chemical nature of your product and the claims made about it are considered when deciding whether your product needs to be registered." Represented as suitable "refers to any written or spoken words in or on the product label or other promotional material (including websites)".

• A disease or condition means registration. "Any product that mentions a specific disease or condition or refers to the prevention, reduction, treatment, alleviation or cure of any disease or condition is considered a veterinary product and requires registration." In the APVMA's examples, "helps maintain healthy bones" is acceptable for a feed; a claim about "primary behavioural disorders or aggression" or "musculoskeletal disease or conditions" isn't. The exception is an excluded nutritional or digestive product whose therapeutic claim meets the conditions below.
• Doses above nutrition, with a cure claim. Among the APVMA's examples of products that claim to cure a condition or disease, aren't provided by a veterinarian and need registration: nutraceuticals such as oral vitamins, minerals, amino acids and fatty acids "when used at daily doses higher than the normal daily nutritional requirement", even where the condition comes from low levels of that nutrient.
• What is in a normal diet is food. Plant or animal material that is an ingredient of an animal's normal diet, and "that is only represented as being suitable and used to help maintain normal (optimal) health, production or performance, is a food and not a veterinary chemical product."
• Natural doesn't change it. "The Agvet Code does not distinguish between naturally derived remedies and synthetic pharmaceutical medicines." The APVMA names "complementary animal health products (including herbal, nutraceutical, direct-fed microbial and homeopathic remedies)" among the products that may need registration.

Animal feed products generally don't need registration, though, in the APVMA's words, "they may be subject to regulation by other Commonwealth, state or territory authorities."

Products the law excludes or lists

• Excluded nutritional or digestive products. Since 5 March 2015, certain feeds for livestock and companion animals are excluded from the Agvet Code. The product "must be one that is fed to, and voluntarily consumed by, an animal and meet specified requirements in relation to ingredients, manufacturing, labelling and claims." It can only make a therapeutic claim if the claim is supported by scientific evidence accessible to the supplier, of a standard "suitable for publication in recognised peer-reviewed scientific journals" and provided to the APVMA on request, or if it is supplied only through the treating veterinarian, with the claims supported by that veterinarian. Its manufacturing options include the Australian Standard for pet food, AS 5812-2023.
• Feed supplements. The APVMA's guidance for a nutritional supplement mixed into feed: it is presented in whole food, a food premix, a block or a lick, or added to feed "(as opposed to being administered in water or as a paste or drench, or by stomach tube)"; its claim is limited to "to supplement diets where levels may be low", or words to that effect; its label carries a statement such as "Nutritional supplement product for inclusion in animal's feed. Product has no therapeutic effect"; and it doesn't use words such as "dose", "dosage" or "administration".
• Listed products: joint health for dogs and horses. Some products are registered as listed chemical products, against a standard the APVMA has set, so a complying product needs no individual assessment. The APVMA's list "currently lists certain home swimming pool and spa products and joint health products for dogs and horses." The only label claim the joint health standard allows is "long term use may help improve joint health and function", and for vitamins and minerals, "to supplement diets where levels may be low".

What registration involves

• Who applies. "Any individual or a body corporate" can apply. Under the Agvet Code, a holder that neither lives nor carries on business in Australia must have an Australian nominated agent.
• The active first. If the product's active constituent isn't already approved, "the APVMA must approve the active constituent before we register the product."
• The data. An application must meet the statutory criteria for safety, trade, efficacy and labelling. For a herbal or marine-derived remedy, the data cover chemistry and manufacture, health (toxicology), and efficacy and target animal safety; for companion animals, data such as residues and the environment "are not normally expected". The toxicology can be addressed by nominating a registered reference product, or by showing the actives are in a registered (AUST R) medicine on the ARTG.
• Manufacturing. "The Agvet Code requires all veterinary chemical products manufactured within Australia to be manufactured in licensed premises, unless those chemical products are listed, reserved or exempt." The standard is the Australian Code of Good Manufacturing Practice for Veterinary Chemical Products 2007, and an imported product must be made to an equivalent standard.
• The label. "The APVMA cannot register a veterinary chemical product without also approving a label", under the Veterinary Labelling Code. A complementary product must carry "This product is registered as a complementary animal health product".

APVMA fees and timeframes

Application	Assessment period	Fee
Approval of a new active constituent and registration of its product (item 1)	18 months	$116,501
A new product with an approved active constituent that no registered product contains (item 3)	18 months	$83,511
A new product whose approved active constituent is already in a registered product, with a full assessment (item 4)	18 months	$44,644
A product similar to a registered product, where chemistry and manufacture, efficacy and target species safety are the only data needed to show it (item 5)	8 months	$7,566
Registration of a listed product, such as a joint health product (item 9)	2 months	$2,632

Each item has further conditions, set out in the APVMA's table. "The legislation prescribes the assessment period for most application types." The APVMA's fees "have not been updated since 2019", and its consultation on the 2027–28 fees, which closed on 4 September 2026, proposes changes "intended to commence from 1 July 2027", including a minimum upfront fee of $2,480 for a veterinary product application.

Pet food and its claims

Most pet food sits outside the APVMA's registration scheme. The APVMA regulates direct-fed microbial, nutritional or digestive pet foods "unless deemed as excluded nutritional or digestive (END) products", and animal feed products generally don't need registration. "States and territories have primary responsibility for overseeing the manufacture and sale of pet food in Australia." The Australian Standard for manufacturing and marketing pet food, AS 5812, is voluntary, though the Pet Food Industry Association of Australia requires its manufacturing members to comply with it. On 24 April 2026 the agriculture ministers "agreed that a regulatory approach is not warranted at this time, based on the available evidence."

Claims are still covered by the Australian Consumer Law: the Competition and Consumer Act "prohibits misleading and deceptive conduct", and the ACCC administers it.

What happens on the wrong side

"Unless we grant a formal exemption or a permit, it is an offence under the Agvet Code to supply a chemical product that is not a registered chemical product where it is required by law to be registered. Monetary penalties apply." In 2024 the Federal Court found that 71 of the 74 products Bonnie & I Pty Ltd advertised on its website, represented as homeopathic or naturopathic remedies, were veterinary chemical products. It ordered the company to pay $850,000, for supplying them, for advertising them and for not complying with a recall notice, and its director $135,000. In September 2025, amending regulations on infringement notices were also registered; their changes are now part of the Agvet Code Regulations.

Human supplements are a different system

The TGA's law is about people: its definition of therapeutic use begins with "preventing, diagnosing, curing or alleviating a disease, ailment, defect or injury in persons". For animals the TGA points to the APVMA, which "assesses veterinary products", and it warns that "you shouldn't be giving medicines made for humans to your pets." For a product for people, see medicine, food or cosmetic?

Where we come in

Our founder, Gabriel Perera, founded Nectar of the Dogs: plant-based supplement powders and water treats for dogs, formulated to evidence-based standards with vet surgeons and naturopaths. In 2022 The Real Pet Food Company, the group behind Ivory Coat, Billy + Margot and Nature's Gift, bought a majority stake, its first move into pet supplements.

So we work on pet products too. They aren't therapeutic goods: where they are veterinary chemical products they follow the APVMA's rules, therapeutic claims get closer scrutiny, and retailers may ask for an evidence dossier. We settle the line at the brief, as we do for products for people: the claims, the doses and the form decide which rules a product meets, before the formula is set. More on formulation, or book a call.