At last, opportunity to overhaul scheduling and S3 advertising for today’s consumer

04 April 2017

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The Australian Self Medication Industry (ASMI) has welcomed the TGA's invitation for feedback on a move towards more widespread advertising of S3 (pharmacist only) medicines. In the consultation document that calls for responses on six different questions on the subject, the regulator noted that "it was widely acknowledged that a ban on advertising of pharmacist-only medicines to the public was unique to Australia". 

ASMI's Marketing and Business Development Director Filomena Maiese said she was "very encouraged to see S3 advertising playing such a prominent and overt role in this consultation",  as the six questions open for discussion represent different facets of ASMI's own proposed model for S3 advertising.

"ASMI's default position is that all S3 medications should be allowed to be advertised unless there are good public health reasons why they shouldn't be. Consequently, our proposed advertising model includes a clearly defined 'non-advertisable' list for products that fits certain exemption criteria such as products with a history of misuse, abuse or diversion for illegal use," Ms Maiese said.

"We also propose that S3 consumer advertising should follow a structured format that includes disease awareness and emphasises the role of the pharmacist."

The proposed advertising model was tested through a discrete choice experiment conducted by the Centre for Health Economics Research and Evaluation (CHERE) at the University of Technology Sydney. The experiment involved 1300 consumers, 500 pharmacists and 500 pharmacy assistants in a randomised study to assess the impact of a 'mock S3 product TV advertisement'. The results made it clear that this advertising format positively influenced consumers' health-seeking behaviour.

Professor Rosalie Viney, Professor of Health Economics and Director of CHERE said there appeared to be no public health benefit from the current restriction on S3 advertising and that the evidence suggested ASMI's alternative model could have a positive impact on the Quality Use of Medicines.

"Unfortunately, there is limited consumer awareness of S3 medicines, so many people don't think to go to a pharmacist for minor ailments that could be treated fairly easily with an OTC, without the need for a GP visit.

"Our research showed that the proposed advertising model significantly increased the likelihood of consumers engaging in more conversations with pharmacists about their health conditions and treatment options," Professor Viney said.

"Importantly, the pharmacists and pharmacy assistants involved in the study were not influenced by the advertising and regularly chose the most appropriate treatment for the consumer."

The TGA consultation also addresses the Scheduling Policy Framework, which determines how different medicines are accessed.  The document discusses the possibility of incentives for switching medicines from prescription only (S4) to OTC (S3). Some of these incentives include mechanisms that ASMI has previously submitted to Government, such as:

  • a proactive S4 to S3 switch committee, which would carry out a "proactive review" of potential candidates for scheduling change (similar to arrangements in the UK, Denmark, Singapore, Ireland); and
  • a period of market exclusivity for the applicant that initiated the rescheduling decision.

ASMI believes that measures such as these, coupled with an alternative set of controls to the current restrictions on S3 medicine advertising, have the potential to reignite both the S3 category and 'switch' - the process of downscheduling prescription medicines to S3.

More switches for Australia will drive greater public health savings. According to research by The Macquarie University Centre for the Health Economy (MUCHE)[i] in 2014, switching 11 prescription-only medicines to OTC showed the potential to produce adirect cost savings of $1.1 billion to the Australian healthcare system - almost $730 million for Medicare and $300 million for consumers. Theindirect value of productivity gains (e.g. reduced sick leave, travel time) was estimated at almost$1 billion per annum.

ASMI's proposed S3 advertising model encourages industry to reinvest back into the S3 category (often considered a 'dead zone' because of the lack of options to increase consumer awareness of products) and provides motivation to 'switch' prescription medicines to OTC.

S3 advertising is also an important driver to maximizing the potential health benefits from a class of non-prescription medicines that are available from pharmacies, but largely invisible to the wider public.

S3 medicines are used to treat everyday conditions including, cold sores, conjunctivitis, mouth ulcers, travel sickness, and nausea and vomiting associated with migraine.


See the UTS CHERE report, 'Estimating the impact of schedule 3 consumer advertising'.

Also: 'Informing consumers about S3 medicines' (infographic) and 'Topline results - S3  advertising research'

See the ASMI mock advertisement designed for S3 advertising.

More about CHERE.



[1]  The Value of OTC Medicines in Australia,The Macquarie University Centre for the Health Economy, March 2014