ASMI comments on TGA Medicine Labelling & Packaging Review Dr Deon Schoombie, Executive Director

25 May 2012

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The label is the primary source of information about non-prescription and complementary medicines and we acknowledge that it is in industry's best interest to ensure that labels convey the information needed to support the safe use of the products.

Consequently, we'll approach the consultation in good faith and based on the premise that this is a genuine dialogue with industry and other stakeholders to find the best way to address issues, rather than "this is what the outcome will look like, say what you like".

Consistent with COAG principles, we support minimum effective regulation, and any regulatory intervention should in our view be transparent, accountable, proportionate, consistent and targeted. We also subscribe to evidence-based decision making and interventions.

The proposals put forward will have to be consumer tested to ensure the readability of labels is not compromised. The visual impact and amount of information on labels are important considerations in label comprehension.

ASMI has over many years advocated the Labelling Code of Practice for non-prescription and complementary medicines and the uptake by industry has been extensive. Labels which conform to the Code have been demonstrated to support appropriate selection and safe use by consumers.

Any change impacting brand names will be a huge issue for industry. The value of a brand name cannot be overemphasised as it determines commercial viability.
For OTC and complementary medicines, brand recognition is crucial. Consumers need to negotiate their way in the pharmacy or supermarket among a vast array of products and product categories to find what they are after. Companies invest heavily in brand design, and maintain the heritage of fonts and colours used in the pack design to attract consumers through brand recognition.

We don't dispute the importance of the prominence of product ingredients to facilitate easy recognition by consumers, but what has been proposed seems completely disproportionate and overly-prescriptive.

We also have serious concerns about changes in relation to brand extensions or "umbrella branding". In some instances, the changes will essentially result in the banning of some products, and this could have legal ramifications.
About ASMI: The Australian Self-Medication Industry (ASMI) is the peak industry body for the Australian self care industry representing consumer healthcare products including over-the-counter medicines and complementary medicines. ASMI's mission is to promote better health through responsible self-care. This means ensuring that safe and effective self-care products are readily available to all Australians at a reasonable cost. ASMI works to encourage responsible use by consumers and an increasing role for cost-effective self-medication products as part of the broad national health strategy.

Media contact: Bob Bowden, Foresight Communications (02) 9241 2811, 0412 753 298