Quality of listed complementary medicines

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ARGCM Part B: Listed complementary medicines

29 October 2017

It is a requirement under paragraph 26A (2) (e) of the Act that each step in the manufacture of a listed medicine in Australia is carried out by a licensed manufacturer (unless the therapeutic good is exempt from this requirement) - refer to Manufacturing therapeutic goods. It is an offence, carrying heavy penalties, to manufacture therapeutic goods for human use without a licence unless the manufacturer or goods are exempt. The manufacturer's licence carries details of the types of manufacture permitted under the licence.

Where a product is imported, each nominated international manufacturer must demonstrate an acceptable standard of good manufacturing practice (GMP) as would be required of an Australian manufacturer. Pre-clearance of international manufacturers is mandatory for listed complementary medicines - refer to Manufacturing standards for overseas manufacturers.

Australia has adopted manufacturing principles for medicinal products for the manufacture of therapeutic goods, including complementary medicines. Each code/quality system sets out requirements relating to quality management, personnel, premises and equipment, documentation, production, quality control, contract manufacture and analysis, complaints and product recall and self-inspection. The observance of these requirements is necessary through all stages of manufacture to consistently provide a high level of assurance of the quality, safety, and efficacy of therapeutic goods. Compliance with GMP and the quality system requirements in Australia is determined by carrying out regular on-site inspections.

Some complementary medicines comprise relatively simple ingredients (for example: amino acids, mineral salts, vitamins) and the quality parameters applying to such products are essentially the same as for other medicines. Special considerations are required for those complementary medicines that contain complex ingredients, that are difficult to characterise, and/or certain combinations of multiple active ingredients.

Guidance on quality for complementary medicines

There are a number of scientific guidelines of particular relevance to listed medicines:

Sponsors and potential applicants should also be aware of the following documents that provide specific guidance for complementary medicines:

Finished product specifications, certificate of analysis

Finished product specifications

The finished product specification is the set of tests and limits applicable to the finished medicinal product in order to ensure that every batch is of satisfactory and consistent quality at release and throughout its shelf life.

The specifications should include all critical parameters in which variations would be likely to affect the safety or efficacy of the product, for example: assay.

The specifications against which a finished product is tested before release for sale are referred to as the 'batch release specifications'. The specifications against which a finished product is tested to ensure satisfactory quality throughout its shelf life are referred to as the 'expiry specifications' or 'end of shelf life specifications'. The product, if tested at any time within its shelf life, must comply with the requirements in the expiry specifications.

Test procedures and Acceptance Criteria for Herbal Substances, Herbal Preparations and Herbal Medicinal Products / Traditional Herbal Medicinal Products CPMP/QWP/2820/00 Rev. 2 provides general principles for setting and justification of a uniform set of specifications for finished products containing ingredient(s) of herbal origin.

Specifications should also take into account Australian legislative requirements for finished products.

The standards recognised under the Therapeutic Goods Act 1989 (the Act) are those made by the Minister under Section 10 of the Act (Therapeutic Goods Orders) and the default standards, which currently are relevant statements in monographs in any of the following: British Pharmacopoeia (BP), European Pharmacopoeia (Ph. Eur.) or the United States Pharmacopeia – National Formulary(USP). It should be noted that any matter specified in an order under section 10 of the Act has precedence over requirements of the default standards.

The general monographs of the BP, Ph. Eur. and USP are also relevant, for example: the BP monographs 'Herbal Drugs', 'Herbal Drug Preparations' and 'Extracts'.

The most recent edition of the cited pharmacopoeia should be used.

Where a finished product does not comply with Australian legislative requirements, for example: Therapeutic Goods Order No. 78 - Standard for Tablets and Capsules (TGO 78), a consent to supply the product is required - refer to ARGCM Part A 'Consent to supply goods that are not compliant with certain legislative requirements'.

Information required for a finished product specification

Product details
  • name of product
  • product code
  • date of specification
  • revision or version number
  • a table listing the tests performed, the expiry requirements or acceptance criteria for the tests (and where different, the release requirements) and reference to the test method (for example: BP HPLC method, 'in-house' TLC method).The tests performed should include the following:
    • appearance of the product [note that the requirements should include: a description of the type of dosage form and any special characteristics (for example: modified release)]
    • physical tests including: average weight, uniformity of weight/ content, disintegration/dissolution (where relevant)
    • chemical tests, including: identification, assay, related substances (where relevant)
    • the microbiological tests
    • any other tests
  • a statement of whether all the tests are performed on each batch of finished product; and if not, what tests are performed on rotation and the frequency.

Certificate of analysis for finished products

A certificate of analysis (used for 'release for supply' purposes) is a document certified as a truthful statement of the tests and test results for an individual, manufactured batch of a particular finished product.

Information required for a certificate of analysis

  • the manufacturer
  • the product name
  • the batch number of the product
  • the date of manufacture of the batch, the date of the testing and the date of the certificate
  • the tests, the tests results, acceptance criteria and a reference to each test method
  • the signature of the appropriate company official.

Use of the term 'quantified by input' for listed complementary medicines

If a manufacturer of a listed complementary medicine meets certain criteria, they may not be required to assay an ingredient in a finished product. The guidance also provides wording that a manufacturer could use on a certificate where an ingredient has been 'Quantified by input' (QBI). Please note that the guidance provided in this document does not override or replace the need to comply with all relevant statutory requirements, nor affect the legal obligations of the medicine's sponsor who is ultimately responsible.

It is intended that this guidance be used by manufacturers, in consultation with the relevant sponsor, as part of product development. It is most relevant where a quantitative claim (see note 1) is made for a particular active ingredient in a listed complementary medicine. However, in certain circumstances, these principles may also be applied to other ingredients or components, including those that are considered to be 'restricted ingredients' (see note 2).


Under good manufacturing practice (GMP), it is a requirement that all active ingredients in medicines be tested to confirm that the content complies with prescribed standards. However, it is recognised that in some circumstances this may not be possible or practical to achieve. Where it is established that such medicines are manufactured in accordance with the principles of the Australian adopted Manufacturing principles for medicinal products and other criteria are met, quantitative testing of the active ingredient in the finished product may be omitted and the ingredient in the product can be 'QBI'. However, based on risk to consumers, it is not appropriate to apply this practice to all ingredients.

If certain specific testing of a listed complementary medicine is not going to be performed, it is important that all other aspects of its manufacture are performed under appropriate GMP. That is, if the finished product is not fully tested, testing of the raw materials becomes more critical. In addition, if there are quantity-based restrictions that affect the medicine's eligibility for listing on the Australian Register of Therapeutic Goods (ARTG), careful consideration needs to be given as to whether reduced testing of the finished product is appropriate.

Where a manufacturer does not intend to assay an active ingredient, or a restricted ingredient or component, in a batch of a complementary medicine, this decision must be supported by written justification. The justification may be reviewed at a Therapeutic Goods Administration (TGA) GMP inspection of the manufacturer or by the TGA during a listing compliance review.

Assessing the suitability of QBI for a listed complementary medicine

When determining whether the content of an active ingredient or restricted ingredient/component in a listed complementary medicine could be QBI, the following points need to be addressed:

  • any quantitative claims made for the ingredient in the finished product
  • any restrictions applicable to the ingredient or any component in the ingredient: these can relate to scheduling entries in the Poisons Standard (see note 3), or be identified in the Permissible Ingredients Determination
  • critical testing of the active raw material, in accordance with GMP principles
  • the availability of a validated assay method for the ingredient/component in the finished product
  • whether QBI would be applied to all batches or only certain batches (testing would be done on a rotational basis).
Complex active ingredients

Many ingredients of biological origin used in complementary medicines are not single component ingredients, for example: shark cartilage, non-standardised herbal extracts. In these situations, where the ingredient/component is not subject to any restrictions and no associated quantitative claims are made in the finished product, the ingredient may be quantified by input. The words 'Not assayed, quantified by input', or words to that effect, may be used on the certificate of analysis of the finished product.

Simple ingredients and components of ingredients

In cases where the active ingredient consists of a single component, or where a quantitative claim is made for any component within an ingredient, it is usually expected that the ingredient/component would be assayed in the finished product. This is particularly important when, to ensure the safety of the medicine, an ingredient/ component is subject to restrictions in any relevant legislative instrument.

However, in certain situations it may be justifiable to QBI such ingredient/components, including those that are restricted, and not assay the finished product. This could occur as part of a rotational testing program (see note 4), where, for certain batches of medicine, the assay of a specified ingredient/component would not be performed. In these cases, a statement such as: 'Quantified by input. This ingredient is part of a rotational testing program and was not assayed in this batch' may be used on the certificate of analysis of the finished product. In some instances, a validated limit test for simple ingredients or components (see note 5) may be able to be used as part of a QBI justification. The use of such a test may provide an acceptable level of assurance that the ingredient/component is below the level which would affect the eligibility of the medicine for listing.

QBI justifications

Difficulties with testing methodologies may be the justification for using QBI for an active ingredient. For example, the formulation of the medicine may be of such complexity that a validated assay method for the ingredient in the finished product is unavailable or is difficult to achieve. To be able to apply the principles of QBI to the manufacture of these medicines, the potency of the ingredient/component must have been established according to the Manufacturing principles for medicinal products prior to inclusion in the formulation. Once this has been done, the words 'Not assayed. Quantified by input' may be used for the ingredient/component on the certificate of analysis of the finished product.

For multi-active medicines (for example: multivitamin/mineral complexes) it may be justifiable to use QBI for ingredients for which a validated assay method for testing the finished product is available. If the quality and safety of the medicine is assured through other testing, the assay of certain ingredients may be put on a rotational testing program. Again, this can only be applied if the potency of the ingredient/component has been established according to the Manufacturing principles for medicinal products prior to inclusion in the formulation. Once this has been done, the words 'Not assayed, quantified by input' or 'Quantified by input. This ingredient is part of a rotational testing program and was not assayed in this batch' may be used for the ingredient/component on the certificate of analysis of the finished product.


Consistent with the principles and guidance in this document, some testing must be performed on each batch of the finished product where a quantitative claim is made on the label. That is, there must be sufficient testing to provide assurance that the product is of intended quality.


Note 1: A 'quantitative claim' is a claim made for a medicine which states that a particular quantity of an ingredient, or component in an ingredient, is present in the medicine.

Note 2: An ingredient, or component within an ingredient, is considered to be 'restricted' where there is a quantity or concentration based restriction referred to in a legislative instrument, such as: the Permissible Ingredients Determination (see definition of 'restricted ingredient' below).

11(2) A substance is a restricted ingredient if:

  1. it is an ingredient in a relevant medicine; and
  2. for that medicine to be, or to remain, eligible for listing, the permissible quantity or concentration of the substance in the medicine is restricted by operation of any of the following:
    1. Schedule 4;
    2. the Poisons Standard;
    3. a condition imposed under section 28 of the Act;
    4. a standard under section 10 of the Act;
    5. the Required Advisory Statements for Medicine Labels document;
    6. any other provision in these Regulations or in the Act that deals with eligibility of medicines for listing.

11(3) In this regulation:

relevant medicine means a medicine that is listable goods or listed goods and that is not an export only medicine.

Where a quantity based restriction may apply to an ingredient or component it is generally not appropriate for that ingredient to be QBI because of the on-going need to confirm that the medicine meets the quantity based restriction and remains safe. This means that any ingredient referred to or mentioned in any of the legislative instruments may generally not be QBI. However, there may be circumstances where, for example, the restriction applies to a component within an ingredient and it can be demonstrated that the concentration is appropriately controlled in the raw material. In these instances, it is possible to apply the principles of QBI and not assay the restricted component in the finished product. Further, if the concentration is significantly below the restricted level, an appropriate limit test could be used on the raw material.

Note 3: A substance may be 'referred' to or mentioned in the Poisons Standard, but it may not be 'included' in a Schedule. That is, it may not be subject to the requirement of the Poisons Standard entry because the quantity/concentration of the ingredient is below that specified in the entry. It should be noted that, by definition, a listed medicine cannot contain any substance that is included in a Schedule. For example: vitamin D preparations are referred to in the Poisons Standard for internal human therapeutic use, although preparations containing 25 micrograms or less of vitamin D per recommended daily dose are not subject to restrictions in the Poisons Standard. Therefore:

  • medicines which contain vitamin D at levels that provide a daily dose of more than 25 micrograms are included in Schedule 4 and cannot be used in listed medicines
  • for listed medicines which provide 25 micrograms or less of vitamin D, a vitamin D assay of the finished product must be performed.

In instances where reference to an ingredient in a legislative instrument only relates to a requirement for a warning statement (for example: Hypericum perforatum in, the Permissible Ingredients Determination) that ingredient may, subject to the principles of this document, be eligible for quantification by input. Please note that this would not be the case if the warning statements are quantity dependent.

Note 4: Rotational testing is the performance of specified tests on pre-selected batches and/or at predetermined intervals, rather than on a batch-to-batch basis with the understanding that those batches not fully tested must still meet all acceptance criteria established for that product. This represents a less than full schedule of testing and should be supported by written justification. This justification may be reviewed at a TGA GMP inspection of the manufacturer or by COMB.

Note 5: A 'limit test' is a semi-quantitative assay for a component in a product. It generally provides a pass/fail result for the component. It should be developed with suitable specificity, precision and accuracy, but it is not expected to provide an exact value.

The use of a validated limit test may provide an acceptable level of assurance that a particular ingredient or component is present in a product at levels consistent with low risk and, subject to the principles of this document, be eligible for QBI. In instances where restrictions in the Poisons Standard or in the Permissible Ingredients Determination apply to an amount of an ingredient/component in a recommended daily dose, the application of a limit test will require knowledge of the recommended dose. In instances where this is not known, manufacturers should liaise with the product's sponsor to ascertain this information.