How long does it take to develop a supplement?
How long a supplement takes depends on where the clock starts and what the formula needs. From our records, a complex herbal capsule went from design to production order in 32 days, and EverLeanBody's first capsule took 5.8 months from signed brief to dispatch. This guide sets out the stages, the TGA's part and what holds a launch up.
In short
- From our records, listed medicines have taken 32 days to 12 weeks from design to production order, and 5.8 to about eight months from brief or formulation to dispatch.
- The stages are the brief and the pathway, the formula, the evidence, stability, the label and the listing, then manufacturing and delivery. Most of them can overlap.
- The TGA's listing step is short. What holds a launch up is a formula that won't run, an ingredient that isn't on the TGA's list, or a pathway settled late.
- A new ingredient needs its own TGA evaluation first: the law allows 40 working days for a preliminary assessment, then 70 to 180 working days for the evaluation.
From our records
How long a product takes depends on where the clock starts. "Design to production order" runs from the start of design to the first production order. "Brief to dispatch" runs from the signed brief to the first batch leaving for the brand's 3PL, so it takes in manufacturing. One record starts at formulation instead.
| Product | Pathway | Time | Measured from and to |
|---|---|---|---|
| A complex herbal capsule built around KSM-66® ashwagandha, with an evidence package covering more than 13 ingredients | Listed medicine | 32 days | Design to production order |
| An eye-health formula, certified halal, in a 60-count pack and a 7-day trial pack | Listed medicine | Under seven weeks | Design to production order |
| A two-a-day probiotic skin supplement, the second version of its formula | Listed medicine | 12 weeks | Design to production order |
| EverLeanBody's saffron capsule, built around affron® | Listed medicine | 5.8 months | Signed brief to dispatch to the brand's 3PL |
| The Belly Solution's travel gut-health powder, in a 14-day pouch | Listed medicine | About eight months | Formulation to dispatch |
Where the time goes
These are the stages a listed medicine is built in. Most of them can overlap: we run formulation, regulatory work and sourcing in parallel rather than in sequence.
- The brief and the pathway. The customer, the claim, the format and the retail price come first, then the pathway: medicine, food or cosmetic. The pathway decides the ingredients you can use, the claims you can make, the label and who regulates you, so it is settled before the formula.
- The formula. Every ingredient, its form and its dose, chosen for the claim and the price the product has to sell at, then samples and a specification a manufacturer can quote. For a listed medicine, every ingredient must already be in the TGA's Permissible Ingredients Determination, and be used within the limits it sets.
- The evidence. Every indication must come from the TGA's permitted list, and the sponsor must hold evidence for each one. The herbal capsule above needed an evidence package covering more than 13 ingredients. More in our claims and indications guide.
- Stability. The TGA says stability evidence should be held at or before listing. If full data aren't ready, older TGA guidance allows an interim shelf life supported by evidence, and real-time testing continues after launch. Our recent stability programs run for 24 or 36 months. More in our stability testing guide.
- The label and the listing. The label is written to the TGA's labelling rules, now TGO 116. The listing is lodged and validated in TGA Business Services, the fee is paid within 14 days of submitting, and the medicine is then entered on the ARTG with its AUST L number.
- Manufacturing and delivery. A cGMP partner matched to the format, the volume and the margin makes the first batch. It is release-tested, imported if it was made overseas, and delivered to the brand's warehouse or 3PL. Unless a step is exempt, every manufacturing step in Australia needs a TGA manufacturing licence, and an overseas site needs a TGA GMP clearance or certification.
What holds a launch up
- A formula that won't run. Another eye-health formula, for a different brand, kept failing in encapsulation because the ingredient mix was too wet, and hand-filling would have added one to two more months. We moved it to a direct-compression tablet, and it shipped in June 2024.
- An ingredient that isn't on the list. A new ingredient needs its own TGA application and evaluation before any product using it can be listed. The law allows the TGA 40 working days for a preliminary assessment, then 70 to 180 working days for the evaluation, depending on the application's level (IN1 to IN4). For 2026–27 the TGA charges $1,370 to apply and $18,456 to evaluate an IN1 or IN2 application, and $3,629 and $30,067 for IN3 or IN4.
- A pathway settled late. A product's pathway turns mostly on how it is presented: its claims, its name, its form, its dose. A claim added after the formula is set can move a product from food to medicine, and with it the ingredients, the label and the regulator.
- A factory without the right clearance. A listed medicine made overseas needs a TGA GMP clearance for the site, which the Australian sponsor applies for. A partner whose site already has the GMP evidence the TGA accepts makes that step shorter; it doesn't remove it.
The TGA's listing step is short
The TGA doesn't individually evaluate a listed medicine before it goes on the ARTG: the sponsor certifies that it meets the rules. Once the application passes validation and the fee is paid, the medicine is entered on the ARTG with its AUST L number, and it usually shows in TGA Business Services the next day.
So the listing itself rarely sets the pace; the work before it does. The TGA sets no timeframe for the sponsor's own work, only for evaluating a new ingredient where one is needed. More on the ARTG and the listing steps.
Foods and cosmetics
A product on the food pathway isn't entered on the ARTG: it must comply with the Food Standards Code. A cosmetic needs no TGA entry either, but the business that imports it or its ingredients, or makes the chemicals in it, registers with AICIS for each year it does. More on AICIS registration.
A food with a novel ingredient has its own step: novel foods must be listed in the Code before they are used. Neither pathway skips the brief, the formula, the label or manufacturing, so the stages above still set most of the timeline.
Where we come in
We run formulation, regulatory work and sourcing side by side, with manufacturing partners already in place, so most stages don't wait for the one before. That is how we take a product from concept to shelf in as little as six months. See the Launch Engine, check the fit or brief a project.
Questions
Frequently asked questions
For a listed medicine, in six stages, most of which can overlap: settle the brief and the pathway, design the formula, build the evidence for its claims, hold stability evidence for its shelf life, write the label and lodge the listing, then make, release-test and deliver the first batch. A food or a cosmetic has no TGA listing, but still goes through the brief, the formula, the label and manufacturing. The pathway comes first, because it decides the ingredients you can use, the claims you can make, the label and who regulates you.
From our records, between 32 days and 12 weeks from design to production order for listed medicines, and between 5.8 and about eight months from brief or formulation to dispatch. The pathway, the formula and the evidence set the pace more than the TGA does, unless a new ingredient has to be evaluated first.
Yes, with a shelf life the evidence supports. The TGA says stability evidence should be held at or before listing, older TGA guidance allows an interim shelf life when full data aren't ready, and real-time testing continues after launch.
A formula that won't run on the machine, an ingredient that isn't in the Permissible Ingredients Determination and needs its own application and evaluation first, and a claim added after the pathway is set. Settling the pathway at the brief avoids the last one.
There's no TGA listing step, but the formula, the label and manufacturing still take their time, and the rules differ: the Food Standards Code for foods; for cosmetics, AICIS registration for the business that introduces the chemicals and the ACCC's ingredient labelling standard. Which pathway a product takes depends mostly on how it is presented, starting with its claims.
Case studies
Case studies
Keep reading
Keep reading
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Skincare, sunscreen and cosmetic product development
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Sources
General information, checked against these sources on 20 October 2026. It isn't advice on a particular product. Timelines are from Take Friday Off's project records.
- Listed medicines and About listed medicines for sponsors, Therapeutic Goods Administration
- General guidance for listed medicines, Therapeutic Goods Administration
- Therapeutic Goods (Permissible Ingredients) Determination (No. 3) 2026, Federal Register of Legislation
- Therapeutic Goods (Permissible Indications) Determination (No. 1) 2025, Federal Register of Legislation
- Listed medicines evidence guidelines, Therapeutic Goods Administration
- Application requirements for new substances in listed medicines, Therapeutic Goods Administration
- Stability requirements for listed medicines, Performing ongoing stability testing and Stability testing of listed complementary medicines (older guidance), Therapeutic Goods Administration
- Therapeutic Goods (Standard for Labelling of Non-Prescription Medicines) (TGO 116) Order 2026, Federal Register of Legislation
- Manufacturing therapeutic goods, Therapeutic Goods Administration
- Fees and charges: summary, from 1 July 2026, Therapeutic Goods Administration
- Food Standards Code, Food Standards Australia New Zealand
- What is registration and who must register?, Australian Industrial Chemicals Introduction Scheme
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