Compounded GLP-1 restrictions and weight-loss advertising enforcement

From 1 October 2024 pharmacists can no longer compound GLP-1 RA medicines for supply. What changed and the TGA weight-loss advertising actions.

11 min read

From 1 October 2024, pharmacists can no longer compound glucagon-like peptide-1 receptor agonist (GLP-1 RA) medicines and supply them to patients. The change, made by amending Schedule 5, item 6 of the Therapeutic Goods Regulations 1990, removed GLP-1 RAs from the pharmacy compounding exemption. It came alongside a run of TGA enforcement action against telehealth services, clinics and a compounding pharmacy over the alleged advertising of prescription weight-loss medicines.

For marketing, the two threads land in the same place. Compounded GLP-1 programs can no longer be lawfully supplied in the way many were promoted, and advertising prescription-only medicines to the public, compounded or not, was already prohibited. Since this change, the TGA has also published guidance on compounded medicines (14 May 2026) and on advertising prescription medicines to the public (18 June 2026), which build on the position described here (see our articles on those topics).

What changed

The compounding exemption

The TGA opened targeted consultation on removing GLP-1 RA analogues from the pharmacist compounding exemption on 29 February 2024. On 22 May 2024, the Minister for Health, Mark Butler, announced that GLP-1 RAs would be removed from the exemption, with effect from 1 October 2024. The Minister’s release said:

  • compounded GLP-1 RA products are not identical to the TGA-approved products and are not clinically evaluated by the TGA for safety, quality or efficacy
  • at least 20,000 Australian patients were injecting compounded products of this kind, mostly for weight management
  • the start date was set to give patients time to consult their doctor and prepare alternative management plans
  • the action would not affect compounded medicines other than GLP-1 RAs.

On 18 June 2024, the TGA confirmed that the amendments to Schedule 5, item 6 had been made. It said they apply to all medicines containing GLP-1 RA analogues, regardless of dosage form, compounded on or after 1 October 2024. The TGA encouraged patients who had been using compounded products to speak to their GP about alternative treatment.

The advertising enforcement

The compounding change did not alter the advertising rules. It is unlawful to advertise prescription-only medicines to the public, and the TGA has said this includes compounded medicines. Around the same period, the TGA announced several enforcement actions. These are allegations; an infringement notice or undertaking is not a court finding.

  • 12 July 2024: 21 infringement notices totalling $319,260 to 4 businesses and 3 individuals, including online telehealth clinics and medical practices offering telehealth, for allegedly advertising prescription-only medicines, mainly for weight loss, on their websites. The alleged conduct included promoting named weight-loss and erectile dysfunction medicines, advertising weight-loss medicines outside their approved indication, stating medicines were “TGA approved”, and stating goods were safe.
  • 1 August 2024: a TGA warning that publicly advertising prescription-only weight-loss medicines is unlawful, and that the Act applies to anyone publishing information about therapeutic goods, including media outlets. The TGA said it had issued over 70 infringement notices totalling over $1 million to 19 entities in the previous 6 months for alleged unlawful advertising of prescription-only medicines.
  • 7 April 2025: a court-enforceable undertaking from Your Solution Compounding Pharmacy Pty Ltd. Between 23 November 2023 and 20 June 2024, its website included order forms for semaglutide and tirzepatide, which the TGA was concerned unlawfully advertised prescription-only medicines. The TGA said the pharmacy acknowledged its website likely did so. The undertaking runs for 3 years and requires external compliance advice.
  • 2 February 2026: infringement notices of $19,800 to telehealth platform Prime Medic Group Pty Ltd and $3,960 to an individual, which the TGA said were paid in January 2026. The TGA alleged the platform advertised prescription-only weight-loss medicines to consumers between at least January and July 2025, and that the advertising included restricted or prohibited representations.

The TGA had earlier warned influencers and advertisers, on 30 November 2022, against publicly promoting a GLP-1 medicine for weight loss.

Who it applies to

The compounding change directly affects pharmacists who compound medicines and the prescribers and clinics who relied on compounded GLP-1 products. The advertising rules apply to anyone who promotes the use or supply of therapeutic goods, which in this area typically includes:

  • weight-loss, metabolic and men’s and women’s health clinics
  • telehealth platforms and online prescribing services
  • GPs and specialist practices
  • compounding and community pharmacies
  • media outlets, influencers and agencies that publish or create content.

What the rules require

No compounded GLP-1 RA supply under the pharmacy exemption

GLP-1 RA analogues compounded on or after 1 October 2024 can no longer be compounded by pharmacists and supplied to patients under the exemption, in any dosage form. This is a supply rule. Any marketing that offers compounded GLP-1 programs describes something that cannot be lawfully supplied that way.

No advertising of prescription-only medicines to the public

The Therapeutic Goods Act 1989 prohibits advertising prescription-only medicines to the public, with limited exceptions. In its YSCP release the TGA said compounding pharmacies may promote their compounding services to consumers but are prohibited from advertising the use or supply of prescription medicines.

No “TGA approved”, “safe” or off-label claims

The July 2024 notices included allegations about stating medicines were “TGA approved”, stating goods were safe, and advertising medicines outside their approved indication. The TGA’s current guidance lists these as separate ways that unlawful advertising may also contravene the Act or the Code.

No restricted or prohibited representations

Claims about treating serious diseases, conditions or disorders need TGA approval or permission. The Prime Medic release included allegations of this kind.

What it means for your marketing

Website and landing pages

Remove offers for compounded GLP-1 programs entirely. Then check for direct and indirect references to prescription weight-loss medicines: trade names, active ingredients, abbreviations such as “GLP-1”, and class terms such as “weight-loss injections”. The TGA’s current guidance lists “weight loss injection” as an indirect reference likely to be treated as a reference to a prescription medicine in context, and images of an applicator pen as an implied reference.

Order forms, booking systems and checkouts

The YSCP matter was about order forms. The TGA’s current guidance also says a public booking system or catalogue that shows the availability of specific prescription medicines may be advertising, as can displaying their prices. If a patient can select a named medicine, a dose or a monthly program before seeing a practitioner, that flow needs rethinking.

Telehealth funnels

The TGA’s current guidance says health services, including telehealth services, that present themselves as a way to obtain specific prescription medicines risk unlawfully promoting those medicines. It gives weight-loss injections as a common example. Promote a consultation about weight management, where a practitioner works out what is appropriate, not access to a medicine.

Paid search and social ads

Ad copy, keywords, display URLs and creative all count. A neutral ad that leads to a landing page naming a medicine is still a problem. Many of the alleged contraventions above came from website content, so review the destination as well as the ad.

Social media and influencers

Do not ask creators to share their weight-loss medicine journeys, show pens, or use nicknames for medicines. The TGA warned influencers about this as early as November 2022.

Email and SMS

Program updates, price changes and “back in stock” messages sent to lists can be mass communications, which the TGA’s current guidance says are unlikely to be exempt.

Media and PR

The TGA has said the Act applies to media outlets. If you arrange coverage, treat the resulting content as advertising for compliance purposes.

What a weight management service can promote

A weight management service is a health service, and you can market it as one. The focus should be the care you provide, not a medicine that may or may not be part of it. That can include:

  • consultations with a doctor to discuss weight and overall health
  • a whole-of-person approach covering nutrition, activity, sleep and mental health
  • the team involved, such as GPs, dietitians, exercise physiologists and psychologists
  • ongoing monitoring and follow-up
  • clear information about how to book, what to expect and what it costs to see a practitioner

It is fine to say that treatment options are discussed and tailored to each person. It is not fine to make a particular medicine, or the chance of being prescribed one, the reason to book.

Claims about results

Weight loss advertising is prone to claims that set unrealistic expectations. Under the general advertising guidelines, avoid promises about how much weight someone will lose or how quickly, and be careful with before and after images and dramatic transformation stories, which can also be testimonials. Outcomes vary between people, and any medical treatment carries risks that belong in a consultation, not glossed over in an ad.

Quizzes and eligibility funnels

Online quizzes that end in “you’re eligible” or that lead straight to a payment page can imply that a prescription is the expected outcome of booking. Frame them as a way to see whether a consultation might be worthwhile, make clear that a practitioner will assess each person, and don’t describe a medicine in the questions or the results.

Common mistakes we see

  • “It’s compounded, so it’s different.” Compounded prescription medicines are still prescription medicines for advertising purposes.
  • Swapping names for descriptions. Replacing a trade name with “weight-loss injections” or “the GLP-1 program” does not avoid the prohibition.
  • Medicine-led programs. Named monthly plans or tiered pricing built around a specific medicine.
  • Eligibility quizzes. “See if you qualify” forms that lead to a particular medicine.
  • Approval and safety claims. Phrases like “TGA-approved medication” or “safe and effective”.
  • Before and after photos tied to a medicine. The TGA’s current guidance says these are likely to be advertising if the result is attributed, expressly or implicitly, to a prescription medicine.

A practical checklist

  • Remove all offers, pages, order forms and price lists for compounded GLP-1 RA products.
  • Search all public content for trade names, ingredient names, “GLP-1”, “weight-loss injection”, “weight-loss shots” and similar terms.
  • Check images and logos for pens, syringes and vials associated with weight-loss medicines.
  • Review booking and checkout flows so patients book a consultation, not a medicine.
  • Remove any “TGA approved”, “safe” or off-label claims.
  • Remove claims about treating serious diseases or conditions unless the TGA has given approval or permission.
  • Review email and SMS templates and automated sequences.
  • Brief influencers, affiliates and agencies in writing.
  • Check archived blog posts, press pages and old campaign landing pages.
  • Keep a record of what you changed and when.

How this fits with other rules

TGA supply and advertising rules. The compounding change sits in the Therapeutic Goods Regulations. The advertising ban sits in the Act. The TGA’s 14 May 2026 guidance on manufacturing, supplying and advertising compounded medicines outlines extra restrictions for higher-risk products, including GLP-1 RA analogues. Its health services guidance says compounded medicines are not exempt from the advertising requirements. In its May 2026 release, the TGA quotes civil penalties of up to $1.65 million per breach for individuals and $16.5 million per breach for corporations.

Ahpra and the National Boards. Practitioners must meet their Board’s code of conduct and advertising obligations, including the testimonial ban. Ahpra’s guidance on prescribing off-label, unapproved or compounded medicines, published on 16 September 2026, names GLP-1 weight-loss drugs among its concerns, particularly in high-volume and single-treatment models.

Telehealth expectations. The Medical Board’s telehealth guidelines, in force since 1 September 2023, say prescribing without a real-time consultation is not good practice and is not supported by the Board.

Frequently asked questions

Can a pharmacy still compound other medicines?

Yes. The Minister said the change does not affect compounded medicines other than GLP-1 RAs. Other compounding remains subject to the existing rules, and the TGA’s 2026 compounding guidance explains them.

Can our clinic advertise weight management services?

Promoting a weight management consultation, without directly or indirectly referring to prescription medicines, is consistent with the TGA’s approach. The issue is presenting the service as a way to obtain a specific medicine.

Can we publish the price of a weight-loss program?

Listing prices for treatments that involve or reference prescription medicines is likely to be advertising those medicines, according to the TGA’s current guidance. Pricing for a consultation itself is a different matter, but take care that it does not reference a medicine.

Does paying an infringement notice mean a business broke the law?

No court has decided the matters described above. An infringement notice is an alleged contravention, and the TGA’s releases describe the conduct as alleged.

Are media outlets covered?

Yes. The TGA said on 1 August 2024 that the Act applies to anyone publishing information about therapeutic goods, including media outlets, and that it had issued infringement notices to a media outlet.

Related articles

Need a hand?

Weight-loss services carry a lot of legacy content: old program pages, order forms and ad variants. Our TGA advertising compliance service reviews these against the current guidance, and our clinic websites team can rebuild booking flows around consultations. For practitioner obligations, our AHPRA compliance audit covers the National Law side.

This article is general guidance based on the published rules, not legal advice. Final responsibility for advertising sits with the registered practitioner, and complex situations may need independent legal advice.

Sources

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