Why is reform to the Agvet Code Needed?

The Australian Pesticides & Veterinary Chemical Medicines Authority’s (APVMA) primary role is to regulate the safety and efficacy of products sold for animal use under the Agricultural & Veterinary Chemical Code (AGVET Code). The moment an animal product makes a therapeutic/physiology claim (mentions parasites or a disease/illness or anything above promoting the normal functions of the body), it is classed as a veterinary chemical product, and triggers full registration, label approval and APVMA-recognised Good Manufacturing Practice (GMP) costs and complexity small natural brands cannot carry.

The Problem for the Natural Industry: The Code wasn’t written with natural products in mind. Its 1990s, claim-based architecture is technology-neutral: it cares what you claim, not whether ingredients are natural. The APVMA’s strict interpretation of the AGVET Code is not in the spirit that the law was intended and in turn, the market is tilted toward pharmaceutical incumbents and leaves the natural/organic sector effectively unrepresented. Still unsure? Consider what APVMA stands for: Australian Pesticides & Veterinary Chemical Medicines.

Lack of a Suitable Pathway: Unlike the Therapeutic Goods Administration (TGA) which offers a Complementary Medicines Listing (AustLII) so that natural products can be listed and regulated for pre-approved, evidence-based mild-claims, the AGVET Code offers no such pathway. The 2015 AGVET Code Excluded Nutritional or Digestive Products (ENDP) update kept genuine nutrition/digestion products out of regulation, but it forbids therapeutic/physiology claims. ENDP helps sell feed, not make health claims (no matter how mild).

Result: By failing to offer a fair, practical, cost-effective path for natural products to be listed or registered with modest claims, the natural/organic sector is effectively unrepresented and at a commercial disadvantage. Additionally, natural and organic companies are being unfairly targeted and harassed in ways that are not in public interest. One such example is Augustine Approved Pty Ltd being issued almost $25,000 in fines for selling certified coconut oil and skincare. Sadly, and ironically, it is ultimately the animals that suffer because people are prevented from knowing about healthy alternatives to pharmaceuticals that can come with a broad and dangerous range of side effects.

The solution: Fix the gap with a TGA-style listed pathway for low-risk companion-animal products: allow mild, evidence-backed claims with proportionate manufacturing practises.

Read the full draft proposal here: https://augustineapproved.com.au/blogs/default-blog/its-time-to-reform-the-agvet-code-a-proposal