TGA policy for the export of medicines from Australia
The export of medicines including prescription, OTC and complementary (eg vitamins, mineral supplements and herbal products) medicines from Australia is regulated by the Therapeutic Goods Administration (TGA) to protect human health and safety by ensuring that medicines originating from this country are of a similar quality and safety standard as those supplied domestically.
The TGA is first and foremost a regulator of medicines for supply in Australia. Exports are important to the future of the Australian medicines manufacturing sector. The TGA is committed to the development of streamlined and responsive regulatory and administrative processes that protect public health and safety and support the export of quality therapeutic goods from Australia.
The key purpose of this document is to delineate the role of the TGA in export regulation. Part A of the document comprises the policy framework or strategic commitments given by the TGA in relation to export regulation. These support and direct the TGA's export-related actions outlined in Part B.
Following the Industry Commission's Report on the Pharmaceutical Industry1 and the Review of the Therapeutic Goods Administration2, the TGA commissioned an independent examination of the regulatory regime for the export of medicines3. This lead to the introduction of new export procedures and initiatives, and re-aligned the then existing export processes, which formed the basis of the TGA Policy for the Export of Medicines that was formulated in 2002. The policy has since been revised on a regular basis.
The TGA Policy for the Export of Medicines from Australia 2007 supersedes the TGA Policy for the Export of Medicines from Australia 2002 and other TGA policy positions and statements on export regulation. The key objective of this policy is to confirm TGA's commitment to protect public health and safety through the export of quality, safe medicines, and to help prevent the manufacture and sale of sub-standard and counterfeit medicines around the world.
The integrity of Australia's export regulatory system - including export certification - relies on the quality of information provided to overseas authorities. The commitment of Australian sponsors to provide high quality factual information in applications supports the reputation of the TGA and the Australian medicine export industry.
An overview of the structure and operation of Australia's medicine regulatory system is routinely included as part of export certification (refer attachment 3). Further operational information on the processes for exporting medicines is also located on the TGA website.
alternate internationally recognised standards such as the United States Pharmacopoeia, European Pharmacopoeia and the Japanese Pharmacopoeia.
- Industry Commission, Report No. 51, The Pharmaceutical Industry, AGPS, Canberra, 3 May 1996
- KPMG, Review of the Therapeutic Goods Administration on behalf of the Department of Health & Family Services, The Department of Health and Family Services, Canberra, January 1997
- T. Hayes, Review of the Regulatory Regime for the Export of Therapeutic Goods, Canberra, September 1997
Part A: Policy Framework
The following strategic commitments are given in relation to export regulation:
A1. Quality and safety assurance for exports
Commitment to the implementation of an export certification system (issued under Section 58 of the Therapeutic Goods Act, 1989) that supports the international competitiveness of medicinal and other therapeutic products exported from Australia through the provision of a suitable standard of regulatory assurance regarding the quality and safety of export goods.
A2. Customer Service andFocus
Commitment to a professional and timely customer focussed service.
A3. Efficiency of domestic regulation
- the majority of medicines exported from Australia are also authorised for supply to the domestic market;
- one of the most important factors for companies maintaining competitiveness in international export markets is response times to export opportunities; and,
- the timeliness of Australia's domestic approval process and the efficient administration of our regulatory system are key factors in enhancing the competitiveness of exporters of therapeutic goods.
A4. International Obligations
Commitment to the protection of public health and safety through the export of safe medicines of an appropriate quality and continued participation in international arrangements that have the objective of preventing the manufacture and sale of sub-standard and counterfeit medicines around the world.
Australia is a participant in the World Health Organization (WHO) Certification Scheme on the Quality of Pharmaceutical Products Moving in International Commerce. The TGA has also assisted in the development of the WHO Guidelines for the Development of Measures to Combat Counterfeit Drugs (1999) and participates in training and surveillance programs to combat counterfeit medicines. Complementary medicines are included in the legislation governing export since the TGA recognises the role of complementary medicines in the general healthcare.
A5. Best Regulatory Practice
One of the goals of the regulation of export certification processes for therapeutic goods is to be consistent with Government regulatory best practice principles4.
Exports are considered one of the drivers of Australia's economic growth. The Australian Government encourages the development of a sustainable manufacturing exports sector and is committed to enhancing the international competitiveness of this sector by reducing regulatory burdens and minimising business compliance costs.
Export regulation of medicines:
- is designed to ensure that medicines leaving Australia meet appropriate safety and quality standards in order to support public health internationally,
- promotes flexibility to encourage the development and manufacture of export product,
- is administered in a streamlined, responsive and timely manner; and
- supports market confidence in the quality of Australian products.
In the interest of supporting trade in quality and safe medicines and ensuring the appropriate understanding of Australia's export certification, the TGA appropriately refers matters to, and liaises with other Australian Government agencies charged with responsibility for trade and industry facilitation.
A6. Risk-based regulation
The risk-based regulation of medicines:
6.1 The level of regulatory control of medicines in Australia is commensurate with the assessed risk posed by the product to public health and safety.
Export medicines are assessed for general safety and must meet standards for quality equivalent to those for the domestic market5.
6.2 Australia recognises that most other countries have their own regulatory systems which take into account national clinical and cultural differences relating to the use of medicines by their community. The regulation of export medicines supports flexibility in working with industry to meet the requirements of other countries while maintaining market confidence in the quality and safety of the product.
A7. Promotion of Australia's quality export certification processes
Promotion of the quality and safety assurance provided by Australia's therapeutic goods regulatory system in consultation with the local therapeutic goods industry.
7.1 The TGA will maintain ongoing contact and discussions with overseas regulatory authorities, the World Health Organization and other international agencies in order to:
- enhance the transparency and relevance of information provided on export certification exchanged between agencies;
- promote confidence in the quality and safety of medicines authorised for marketing in this country and/or intended for export; and
- as appropriate, reflect the outcomes of these processes in exchanges of letters and agreements on export certification.
7.2 One of the primary reasons for the initial adoption of the WHO Certification Scheme on the Quality of Pharmaceutical Products Moving in International Commerce was to ensure that all countries have equal access to information on the quality and safety of imported medicines. The TGA recognises that many countries are working progressively towards implementation of appropriate regulatory systems and that there are varying degrees of reliance placed on export certification from the exporting country. However, in support of the objectives of the WHO scheme, the TGA communicates appropriate additional information to overseas authorities, via export certificates. Australia respects the regulatory systems of other countries and regulatory agencies in export destinations have full discretion in the use of the information provided on certificates.
- Principles and Guidelines for National Standard Setting and Regulatory Action by Ministerial Councils and Standard Setting Bodies/by Council of Australian Governments (COAG), Canberra: COAG, 2004
- Therapeutic Goods Order No.70 B for export only medicines permits the export of medicines which meet specific
Part B: TGA Export-related regulatory and administrative processes
The TGA's regulatory and administrative processes relating to the export of medicines are underpinned by the framework provided by the Policy for the Export of Medicines from Australia.
This section outlines the activities of the TGA in its role as:
- the regulator for medicines for export, and
- a point of support and referral for exporters of medicinal products regarding trade and industry issues relating to the export regulatory environment for medicinal products.
B1. Regulatory Role
- Requires that medicines exported from Australia comply with necessary quality and safety standards;
- Approves the supply of medicinal products in Australia and for export;
- Issues export certificates (including certificates issued under the WHO Scheme); and
- Communicates with other regulatory authorities to maintain awareness of any potential quality and safety issues.
1.2 Evidence based decision making
Documented evidence is considered in relation to the application of required product standards and manufacturing principles and product presentation and representations that may influence safe use. The TGA decision to approve medicines for export is based on whether this documented evidence in conjunction with certain assurances from the exporter are sufficient to support the quality and safety of the medicine.
1.3 Medicines approved for supply in Australia which are exported
Medicines permitted for supply to the Australian domestic market are automatically permitted for export by the sponsor or their agent, subject to other applicable export legislation such as Customs, Quarantine, and Environment Australia etc.
Many medicines exported from Australia fall into this category, that is, they have an authorisation to supply to the domestic market. The only allowable differences between the product permitted for supply in Australia and the product being exported6 are:
- the name of the product;
- certain minor differences to the label of the product7.
In some cases approval to supply the product in Australia is subject to inclusion of specific label warning statements. If the product is also to be exported, these warning statements must remain on the label in order for the Australian approval to extend to the exported product. Warning statements may only be omitted where the product is solely for export.
1.4 Quality and safety requirements for export medicines
Medicinal products for export from Australia that are manufactured exclusively for export and can not be supplied in Australia including Australian duty free outlets, and that have to be listed 'as export–only medicines or solely for export medicines', must8:
- comply with required quality standards and prescribed quality and safety standards;
- be manufactured according to Good Manufacturing Practice (GMP GMP) principles9;
- be of acceptable presentation and not make false or misleading representations;
- be safe for their intended purposes; and
- not have been imported without an appropriate import licence or permit where required under Australian Customs legislation.
Medicinal products which are not finished products as they are exported in bulk and then packaged/labelled and released for sale overseas are required to be approved by the TGA for export.
Many export products are similar to products sold on the Australian market (for instance, they may have minor variations to formulation, different presentation or are transported in bulk). Some higher risk products (which would require a full evaluation for approval for supply in Australia) may have exactly the same formulation but are not considered to be the same product if they are packed in different container types (eg bottles, blister pack, bulk pack etc).
Label warning statements
Often warning statements are associated with the types of indications permitted for the product within the regulatory framework of the destination country (eg depending on whether the product is regulated as a food or drug on the export market). While product labels must be submitted for medicines assessed under Section 26 of the Act, these labels are not assessed for the presence of appropriate warning statements. And, if a product is assessed under Section 26A, labels are not required at the time of listing. However, considering the growing number of warning statements that are required in Australia for non-prescription medicines, it is expected that sponsors will act responsibly and include appropriate warning statements which are relevant to the safe use of the product for the intended overseas market. The following condition of listing applies to export medicines approved under Section 26 or Section 26 A of the Act: 'It is the responsibility of the sponsor to ensure that any necessary warning statements are included on the product label as required by the destination countries'.
The Australian standard (ie the Therapeutic Goods Order No. 69) for labelling of goods for supply in Australia is not applicable to labels for export medicines.
Material of human/animal origin
The TGA approach to minimising the potential risk of exposure to Transmissible Spongiform Encephalopathies (TSEs) through the use of medicines also encompasses export medicines. Products which contain any human material or materials identified in Category 1 or 2 of the European Guidelines (ie high and medium infectivity risk) require a pre-clearance through the Therapeutic Goods Administration Laboratories (prior to submission of the listing application).
If the product contains certain ingredients of human/animal origin that may potentially transmit TSEs, sponsors will be asked to provide details of the specific species/tissues and the country of origin in the electronic listing application. These and other details such as the source of feed for the animals and the health status of the animals as certified by a veterinarian should also be provided to the TGA Laboratories as part of the process of obtaining a Pre- clearance for the use of the animal origin ingredient in the export product formulation.
If the country of origin is not a known BSE-free country, the application will be referred to TGAL for further assessment. A statement of compliance with the joint Committee For Veterinary Medicinal Products (CVMP) guideline for minimising exposure to TSE agents may be submitted to support the application.
The guideline, Note for guidance for minimising the risk of transmitting spongiform encephalopathy agents via human and veterinary medicinal products was issued by The European Agency for the Evaluation of Medicinal Products (EMEA/410/01 – FINAL). It is available on the The European Agency for the Evaluation of Medicinal Products website.
If the product contains material of animal origin which has been assessed as having a low risk of possible transmission of TSEs or has not yet been assessed by the TGA the sponsor must hold details on the species of animal, tissue and country of origin.
Presentation of the product includes the product's name, packaging, labelling (content not format) and design of the dosage form. The TGA assesses this material to make a decision on the acceptability of the medicine's presentation and safety for intended purpose of use.
The TGA will not accept presentation of a medicinal product that:
- is misleading, confusing or false, that is, it suggests it has ingredients or characteristics which it does not ; and/or
- promotes itself as a treatment for a serious disease such as cancer, asthma or HIV where the TGA is of the view that there is insufficient evidence of efficacy for these conditions; and/or
- is likely to be confused with toys, food or confectionary; and/or.
- does not reveal all the active therapeutic ingredients it contains.
If the presentation of the product is unacceptable in the Australian context, the overseas authority will be informed of any concerns via the Export Advisory Procedure (see Section 1.5.1 below).
Intellectual property right issues are the responsibility of the patent holder and the agencies charged with administration of patent legislation. However, sponsors of new listings are required to submit with their application a declaration notifying either a patent is not wilfully being infringed upon or that such a declaration is not required. Further information in this regard including the necessary forms is available on the Australia-United States Free Trade Agreement page.
1.5 Notification of additional information to overseas destinations
Where the TGA makes a decision that the relevant authority in the destination country should be advised on specific issues with regard to an export medicine the Export Advisory Procedure or Safety Approval Process will be used.
1.5.1 Export Advisory Procedure
The Export Advisory Procedure is a mechanism for communication between the TGA and the country of receipt of the goods via conditions of listing which may be imposed on the supply of the product or as a statement in the export certificate. Under this procedure the responsibilities of the sponsor are outlined as a condition of listing on the Export Listing Certificate (Certificate of Medicine Listing for Export Only) and details of specific issues included in any Certificate of Pharmaceutical Product issued for the product under the auspices of the World Health organisation. The Export Advisory Procedure will generally be used where there is:
- no comparable product on the Australian market in terms of ingredients, significant quantity of active ingredients, routes of administration; or
- the indications are contrary to those published in recognised scientific references; or
- the presentation of the product would be unacceptable for the Australian market; and
- there are no serious safety concerns.
In determining the safety of products containing substances which have not been evaluated by the TGA for use in therapeutic goods in Australia, the following factors will be considered:
- the availability of the substance in other countries with comparable regulatory systems (eg USA, UK, Canada, Switzerland, The Netherlands, Sweden and New Zealand); and/or
- any concerns identified in a limited search of scientific literature databases; and/or
- any other information relevant to the substance.
Where the substance is available in other countries and there are no safety concerns (eg toxicity, adverse monitoring reports) related to the substance, identified through online searches of well recognised scientific references (such as the US FDA website, Micromedex / Toxnet / Complementary & Alternative Medicine Databases) the following condition of listing applies:
'Where the product is considered to be a food in the destination country, the sponsor must ensure that the product meets any relevant food standards. Where the product is considered to be a medicine in the destination country, the sponsor must advise the regulatory authorities that the product contains a substance which has not been evaluated for therapeutic use in Australia'.
The availability of the substance in the country to which the product is being exported will also be considered in determining whether application follows the Export Advisory Procedure or the Safety Approval Process.
1.5.2 Safety Approval Process or refusal to list
The TGA reserves the right to refuse export authorisation outright where the safety of a medicine is of sufficient concern, or to require either:
- evidence provided by the sponsor from proper authorities in the export destination that it will allow import of the medicine in question; or
- written confirmation to the TGA from the authority in the export destination that it will allow the import of the medicinal product (known as the Safety Approval Process)
TGA concern regarding the safety and quality of a product will be based on one or more of the following factors:
- the product contains an entity which has not been assessed for therapeutic use in Australia and there is well documented evidence of serious toxicity or adverse reactions; or
- domestic supply/registration of the product has been rejected in Australia due to (specified) safety concerns; or
- lower risk medicines are making claims for the treatment of serious conditions (eg diabetes, heart disease, HIV); or
- the risk of toxicity to the target group indicated on the label (pregnant women, children etc) is unacceptable as supported by well documented evidence; or
- the Good Manufacturing Practice of the manufacturer/s has not been established or is unacceptable; or
- the TGA has other serious safety concerns with the product as supported by well documented scientific references.
Any evidence which is submitted indicating that the country of receipt is prepared to accept the goods or to justify the appropriateness of the quantity of active for the target group (in the context of the overseas market) will be considered prior to deciding to use the Safety Approval Process. Where this information can be submitted it is likely that the Export Advisory Procedure would be used instead. If the TGA is of the view that the product is not safe for the intended purpose of the product or the importing country has not indicated their willingness to accept the goods under the Safety Approval Process, the application for listing will be refused.
Sponsors will be formally notified of any intended course of action and have an opportunity to comment before a final decision is made.
Attachment 2 outlines the decision process in considering approval for the export of medicines which contain a substance that has not been evaluated for therapeutic use in Australia.
1.6 Export Certification
The TGA issues three types of export certificates for medicinal products:
- a World Health Organization (WHO) Certificate of Pharmaceutical Product (CPP) (for products permitted to be supplied in Australia or for products authorised for export – refer to example attachment 3);
- a TGA Export Certificate of a Listed Product (for lower-risk products permitted to be supplied in Australia – refer to example at attachment 410); and
- a TGA Export Certificate of an Exempt Product (for products not required to be entered in the Australian Register of Therapeutic Goods but still subject to therapeutic goods legislation). This certificate is generally designed for exempt medicines which are manufactured in a GMP licensed manufacturing facility. In this situation, the standard of manufacture may be certified in accordance with the WHO model.
1.6.1 Purposes of export certification issued by the TGA
The purpose of export certification is to:
- enable the international monitoring of trade in medicines to ensure that the safety and reliability of products is maintained;
- provide appropriate and useful regulatory support to overseas health authorities. (Information may be included in certificates to assist authorities to properly determine the safety/quality status of a medicine in the context of their own market);
- enhance the confidence of overseas regulatory authorities in the quality and safety of Australian medicines permitted for export; and
- be relevant in the international market place and acceptable to authorities in export destinations.
1.6.2 Information able to be certified
The WHO Export Certification Scheme was put in place to provide assurance regarding the quality and safety of pharmaceuticals being traded internationally for countries that do not have regulatory arrangements to undertake assessments themselves. The basis of the Scheme is formed by WHO endorsed requirements for Good Practices in the Manufacture and Quality Control of Drugs.
The Scheme is an administrative instrument that requires a participating country, on application from a product sponsor, to certify to another country that:
- a specific product is authorised to be placed on the market within its jurisdiction or, if it is not, the reason why; and
- the plant in which it is produced is periodically subject to GMP inspections; and,
- that all aspects of the manufacture of the product are satisfactory.
If the GMP status of any manufacturers nominated in the export certificate is ‘Unacceptable', a CPP or CLP cannot be issued until these matters have been resolved and a Certificate of GMP for the manufacturer has been forwarded to the Export Medicines Unit.
The Guidelines on the Implementation of the Scheme can be located on the World Health Organisation website.
In accordance with the WHO Scheme, the following information will be certified by the TGA:
- (export) name and dosage form of product;
- formulation composition;
- regulatory status of the medicine in Australia, including AUSTL/AUST R number and date entered in the Australian Register;
- name and address of sponsor;
- name and address of manufacturer(s) involved in all steps of manufacture; and
- GMP compliance for all manufacturers as requested by certificates
- shelf life and storage conditions for registered products, where these details are held as part of the ARTG record; and
- the product label as currently authorised for the Australian market.
If a sponsor wishes to attach a TGA approved product information (PI) for a registered medicine, the TGA will indicate on the certificate that a notarised copy of the TGA approved PI is provided by the sponsor10.
While certification is limited to the above documents, in accordance with the WHO Scheme, the TGA recognises that some countries require the competent authority in the exporting country to stamp additional documentation. These additional documents may be submitted for stamping as 'Seen by TGA' but will be clearly identified as not being part of certification under the WHO Scheme. These documents may include:
- product specifications
- product information which has not been approved by the TGA (eg for products listed for supply in Australia)
- Certificates of Analysis
- test methods
- shelf life and storage conditions (for products other than as described above)
At the same time, the TGA will also enter into discussions with these countries to gain a better understanding of the need for such documentation. Documentation which does not directly relate to the regulation of the product by the TGA (eg trademarks, pricing, subsidiary addresses etc) cannot be included as an attachment to a CPP.
To assist communication with overseas regulators regarding the circumstances of the product, the TGA has included the option for exporters to, within the electronic certificate application, select a codified statement12 on CPPs for export products.
Sponsors are required to sign a declaration at the time of application submission that information in applications for export certificates is truthful and accurate.
Certification of product labels
If sponsors wish the TGA to certify product labels for products approved for supply in Australia, the Australian approved product label must be submitted. However, a second label may also be submitted specifically for the destination country which includes the statement, 'label for [name of country]'. This label will be attached to the CPP but not certified by the TGA.
Where the product is listed for supply in Australia and an 'Australian' label does not exist, a draft label which includes relevant warning statements may be submitted for certification which includes the statement 'draft label for Australia'. Alternatively, where the overseas label has not been finalised, a statement may be included above the Australian approved label as per below:
The label for the importing country will be based on this label, amended as necessary to meet local commercial and regulatory requirements.
Records in the Australian Register of Therapeutic Goods (ARTG)
The TGA recognises that maintaining the quality of the data in the ARTG is a shared responsibility of the TGA and sponsors. The TGA is committed to assisting sponsors with the resolution of problems with ARTG records. To facilitate speedy processing of export certificate applications, sponsors are requested to correct discrepancies between their records and the ARTG, with the Register and/or relevant areas in the TGA prior to requesting an export certificate.
If an overseas destination requests additional information from the TGA:
- the sponsor may obtain it directly from the relevant area of the TGA, or
- the overseas agency is welcome to obtain it directly from the TGA with the written consent of the sponsor.
Such information and any other information the sponsor wishes to submit to the overseas authorities is considered to be separate from the export certificate.
- Refer to Section 16 of the Therapeutic Goods Act 1989 and Therapeutic Goods (Groups) Order No. 1 of 1992.
- Label claims must be consistent with the indications included for the product in the Australian Register of Therapeutic Goods
- Export-only medicines are listed on the Australian Register of Therapeutic Goods under Section 26 of the Therapeutic Goods Act 1989 (the Act), whereas Solely for Export medicines are listed under Section 26 A of the Act (Refer Section 26 and Section 26 A of the Therapeutic Goods Act 1989)
- GMP evidence is not required for the manufacture of active raw materials
- TGA Export Certificates (as opposed to a WHO Certificates of Pharmaceutical Product) are not and do not purport to be WHO CPPs. TGA Export Certificates have been designed for medicinal products for which a WHO CPP is not necessarily appropriate as they are not conventionally classed as 'pharmaceutical products' e.g complementary medicines.
- As priority in the design of the electronic lodgement system has been given to streamlined and responsive handling of export certification applications, the TGA will not certify the PI documents.
- A list of the codified statements is included at attachment 1
B2. Support Role
2.1 Communication and Consultation
The TGA is committed to consistent interaction with other regulatory authorities on issues of export regulation through an active program promoting Australia's export certification system.
Export certification matters will also be discussed, with overseas visitors to the TGA.
The TGA will develop material explaining Australia's export certification processes for distribution to overseas regulators. The TGA website will provide up-to-date information on export certification policies and processes.
2.2 Advice and Referral
The TGA will assist sponsors, wherever possible, by providing advice and referral for Australian exporters of therapeutic goods in relation to the export regulatory environment for therapeutic goods.
In relation to market entry matters the TGA will:
- refer cases to Australian trade and industry officials (including Department of Foreign Affairs and Trade and Austrade ) for resolution; and/or
- undertake discussions directly with overseas authorities on regulatory matters.
For issues with wider regulatory implications, the TGA will consider raising a matter in bilateral and multilateral forums and the negotiation of formal arrangements with regulatory authorities.
The TGA will work with industry associations and government agencies to ensure the provision of education and training programs for industry that enhance their knowledge and expertise in export regulatory issues.
Attachment 1: Codified sponsor statements
CPP for Export products
The statements below appear on the CPP electronic certificate application forms for export products that are manufactured only for export purpose and can not be supplied in Australia. Sponsors/agents of sponsors may only select one statement, which is in most agreement with the market situation of their export product. If none of the statements suits to the product situation, sponsor or agent of sponsor may select 'other' option and provide their own statement. The TGA will include this statement on the CPP if it agrees with the statement. The statements are:
- This product has been developed exclusively for the treatment of conditions, not endemic in Australia, and as such listing/registration for the Australian market is not requested.
- This product has been developed exclusively for the importing country and as such listing/registration for the Australian market is not required.
- This product has been repackaged to meet the importing country's requirements.
- The product approved for supply in Australia has been reformulated to exclude excipients not approved in the importing country.
- This product has the same formulation as another product on the Australian market (AUST L / R…..) which is supplied in a different container or packaging.
- This product does not require marketing approval in Australia as it has been manufactured for an overseas principal. It is being transported in bulk.
- Listing/registration for the Australian market has not yet been requested for commercial reasons.
- This product is approved for supply in the following markets (insert countries).
CPP for products registered for supply in Australia that are intended to export
- This product is approved for supply in Australia but is not marketed at present for commercial reasons.
Attachment 2: Assessment path for export medicine containing a new substance not evaluated for therapeutic use in Australia
This text representation of this flowchart is provided as a list with numbered steps.
- Evaluated for therapeutic use in Australia?
- Yes - Acceptable ingredient - End flow chart
- No - Go to Step 2
- Approved in USA / UK / Canada / Switzerland / New Zealand / The Netherlands / Sweden?
- Yes - Export Advisory Procedure
- condition of listing to inform authorities in importing countries
- TGA comment 'not evaluated for therapeutic use in Aust' on CPP - End flow chart
- No - Go to Step 3
- Yes - Export Advisory Procedure
- Approved in country of receipt?
- Yes - Export Advisory Procedure
- condition of listing to inform authorities in importing countries
- TGA comment 'not evaluated for therapeutic use in Aust' on CPP
- Only for export to this country
- If there are safety concerns - End flow chart
- No - Go to Step 4
- If there are safety concerns Safety Approval Procedure applies
Serious safety concerns (eg Hazardous chemical rating, associated with death, illnesses) Listing is refused