Submission on Improvements to the Therapeutic Goods Advertising Code

The Australian Multicultural Health Collaborative (the Collaborative) welcomes the opportunity to comment on the Therapeutic Goods Administration’s (TGA) consultation on targeted changes to the Therapeutic Goods Advertising Code. As the national multicultural health peak body, the Collaborative’s focus is on whether the proposed changes support safe, informed and equitable decision-making for consumers from culturally and linguistically diverse backgrounds.

Australia’s population is highly culturally and linguistically diverse. The 2021 Census found that 51.5 per cent of Australians were born overseas or had at least one parent born overseas, and more than 5.6 million people used a language other than English at home (Australian Bureau of Statistics, 2021 Census). The Collaborative consults multicultural populations as part of its programs and in its roles as a multicultural health peak body and the peak body for multicultural affairs and multicultural seniors and older Australians. Through this work, communities have consistently identified language and literacy barriers, difficulty navigating health services, and variable access to culturally responsive information as continuing system-wide challenges.

For therapeutic goods advertising, these barriers have practical regulatory implications. Mandatory statements, warnings and disclosures only protect consumers if they can be readily noticed, understood and acted upon. The Collaborative therefore supports reforms that improve transparency and consumer safety, while also ensuring that required information is accessible across language, health literacy and digital literacy.

This submission draws on recurring themes from the Collaborative’s broader engagement with multicultural consumers and organisations. It responds directly to the consultation questions where the Collaborative has a relevant consumer or equity perspective. Where we do not identify a specific concern, we have said so rather than extending beyond the evidence available to us.