Compliance guide
Restricted and Prohibited Representations Explained
Quick answer — What is a restricted representation?
A restricted representation is a reference in advertising to a serious form of a disease, condition, ailment or defect — one requiring diagnosis or treatment by a qualified health professional. Using one in an advertisement to the public without prior TGA approval is unlawful. Conditions like cancer, PTSD, epilepsy, chronic pain, anxiety and depression fall in this territory, and references to them are the most common basis for medicinal cannabis advertising fines.
The two categories and where the line sits
Restricted representations concern serious conditions that need professional diagnosis or treatment; they can only be used in advertising with prior TGA authorisation, which is rarely granted. Prohibited representations are a narrower class — including references to certain diseases like cancer — that are essentially never permitted in consumer advertising.
For medicinal cannabis the distinction is mostly academic, because the products are prescription medicines that cannot be advertised to the public at all. In practice, a condition reference compounds the breach: the TGA's infringement notices routinely cite both the advertising of a prescription medicine and the use of restricted or prohibited representations, which is partly why per-business penalties run large — Better Leaf and an individual drew $171,972 across their notices, and Dispensed drew $118,800 plus a direction notice.
Where condition references hide on real websites
Audits rarely find condition references only on the homepage. The recurring hiding places: service menus ('support for chronic pain patients'), practitioner bios ('special interest in anxiety management'), FAQ answers, blog archives from before the current marketing team, meta titles and descriptions written for SEO, image alt text, embedded review widgets where patients mention their conditions, and booking-flow dropdowns asking what you're seeking help with.
Linked content counts too. TGA guidance uses the example of a site that links to an overseas blog promoting cannabis for osteoarthritis pain — the link makes the original site an advertisement.
Writing around the problem
The lawful pattern is to describe the service, not the condition or the treatment: consultation model, practitioner registration, appointment logistics, fees. Balanced, non-promotional educational material that discusses a range of treatment options without emphasising cannabis benefits sits outside the advertising definition in TGA guidance examples — but the balance test is strict and easy to fail, which is why we recommend auditing any educational content rather than assuming it qualifies.
Frequently asked questions
Can we get TGA approval to use a restricted representation?
Approval exists in principle for public-health reasons but is rarely granted, and it would not cure the underlying prohibition on advertising a prescription medicine.
Do testimonials that mention conditions count?
Yes — a patient review saying cannabis helped their pain, displayed on a page you control, is both a testimonial breach and a condition reference.
Are conditions in URL slugs and meta tags a risk?
Yes. Anything a consumer can see in search results or on the page is part of the advertisement, including titles, descriptions and slugs.
Is 'sleep support' or 'stress' safer than 'insomnia' or 'anxiety'?
Softer synonyms reduce but don't remove risk when the overall context signals cannabis prescribing. The test is what a reasonable consumer takes from the whole page.
Check where you stand
The breach patterns in this guide are exactly what our audit engine checks. Start with the free 10-point self-assessment, a $149 rapid scan, or the $449 full audit. Everything is delivered by email.