Pharmacies warned not to use price comparisons, incentives, misleading statements or claims to promote use of vaccines
The TGA has reminded immunisation providers “including pharmacists and pharmacies” to be aware that advertisements for vaccines are subject to the therapeutic goods legislation and must comply with the Therapeutic Goods Act 1989 and the Therapeutic Goods Advertising Code.
While the Act does not regulate the advertising of health services, any advertisement of a vaccination service that also promotes use of a therapeutic good (i.e. the vaccine) may be covered under the Act and the Code.
The TGA advises those who are advertising vaccination services to avoid using:
- information that might enable consumers to identify the particular vaccine or the manufacturer/s of the vaccine/s provided with the service;
- statements or representations that harmful effects will occur from not receiving the vaccine;
- references to any misleading therapeutic benefit of a vaccine (for example, a use that is not a TGA-approved indication for the vaccine);
- an indication that the vaccine administered as part of the service is superior to other vaccines;
- portrayals of the vaccine or service in a way that trivialises or conflicts with public health policies, or misleads consumers in any other way;
- price comparisons;
- incentives to encourage the consumer to obtain the service or vaccine; or
- any other claim that promotes the use or supply of the vaccine.
“Use of any of the above makes advertising of your service to be more likely considered advertising of the vaccine itself and subject to therapeutic goods legislation,” advises the TGA.
The organisation also recommends that advertisements for seasonal influenza vaccination services should inform consumers that:
- the vaccine is either a “trivalent vaccine” or “quadrivalent vaccine”
- influenza vaccines are free to people from high risk groups identified in the National Immunisation Program (NIP)
- people from high risk groups should seek advice from their medical practitioner
High risk groups that are eligible for free influenza vaccines under the NIP include:
- people aged 65 years and over
- Aboriginal and Torres Strait Islander people aged 0 to 5 years
- Aboriginal and Torres Strait Islander people who are aged 10 years and over
- pregnant women
- people aged six months and over with medical conditions such as severe asthma, lung or heart disease, low immunity or diabetes that can lead to complications from influenza