Clarifying eligibility for origin claims in the Complementary Medicines Sector

Response 927126422

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Introduction

1. Who are you responding on behalf of?

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Ticked Individual
Organisation

2. What is your name?

Name
Mrs Inge Saul

6. Submission

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Ticked Questions for consumers
Questions for manufacturers of complementary medicines
Questions for businesses who are not manufacturers of complementary medicines

Questions for consumers

1. Do you consider that a product regulated by the TGA and manufactured in Australia from imported ingredients should be eligible to use the AMAG logo?

Please select one item
Yes
Ticked No

2. Would you consider a complementary medicine, made primarily from imported ingredients to be ‘Australian Made’ if key steps in the manufacture of the medicine into its final dosage form (e.g. manufacture of the pill, capsule etc.) takes place in Australia?

Please select one item
Yes
Ticked No

3. What proportion of total ‘manufacturing’ of a product do you consider should take place in Australia to qualify for meeting a substantial transformation test and an ‘Australian Made’ claim?

What proportion of total ‘manufacturing’ of a product do you consider should take place in Australia to qualify for meeting a substantial transformation test and an ‘Australian Made’ claim?
The ingredients need to come from Australia

4. Option 2 involves the industry developing its own symbol to designated products as Australian Made. Would such a symbol help you understand the country of origin of a product, or would the AMAG logo be a better indicator of a product’s country of origin?

Please select one item
Ticked New symbol
AMAG logo

5. If complementary medicines consist primarily of imported ingredients, should this be acknowledged on the label?

Please select one item
Ticked Yes
No

6. If imported ingredients had to be acknowledged on the label of the product, would you prefer?

Please select one item
Ticked A statement acknowledging that the product consists of imported ingredients (Option 3b)
A ruler/bar chart (or similar symbol) showing the proportion of imported ingredients in the product (similar to the ruler/bar chart used on food products) (Option 3c)
A different form of acknowledgement of imported ingredients - please provide details.
A different form of acknowledgement of imported ingredients - please provide details.
There needs to be a clear statement and/or bar chart relating to the origin of all ingredients; not just significant ingredients. This needs to apply to health food supplements just as it does to other foods we consume.

7. Do you consider that Options 3b and/or 3c, if instituted, would diminish or improve the perceived value and status of the AMAG logo?

By how much would the value/status of the logo be diminished?
Please select one item
 Ticked None A little Somewhat A lot
By how much would the value/status of the logo be improved?
Please select one item
 None A little Somewhat Ticked A lot

8. A fully formed meat pie can be imported and then cooked in Australia and meet the current substantial transformation test. It is then also eligible for use of the AMAG logo.

Do you consider this pie to be more or less ‘Australian Made’ than a complementary medicine consisting of imported ingredients but produced through a TGA certified Australian manufacturing facility?
The current 'substantial transformation' test is obviously problematic and can be rorted to the vendor's advantage to gain Australian Made endorsement.