Complementary Medicines Australia - Treasury

Complementary Medicines Australia

2018/19 pre-Budget Submission

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2018/19 Federal pre-Budget Submission

December 2017

Mr Carl Gibson

Chief Executive Officer


Published by: Complementary Medicines Australia

PO Box 450

Mawson, ACT 2606

Australia

Telephone: 02 6260 4022

E-mail: [email protected]

Website: www.cmaustralia.org.au

Australia’s Complementary Medicines Industryi:

$4.7 billion complementary medicines industry revenue, having doubled from $2.3 billion in just three years

Vitamin & dietary supplement category alone has doubled over the last ten years

Complementary medicines exports have doubled over the last three years

82 TGA licensed manufacturing sites in Australia

12 700 direct high skilled jobs in complementary medicine products industry

36 441 employees across 29 natural therapy modalities

© Complementary Medicines Australia (2017)

mailto:[email protected]

http://www.cmaustralia.org.au/



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Introduction

Complementary Medicines Australia (CMA) is the peak industry body for the

complementary medicines industry, representing stakeholders across the value chain,

including manufacturers, raw material suppliers, distributors, consultants, retailers, allied

health professionals and educators. CMA promotes appropriate industry regulation and

advancement to ensure consumers have access to complementary medicines of the highest

quality.

Regulated in Australia as medicines under the Therapeutic Goods Act 1989, complementary

medicines include vitamins, mineral and nutritional supplements, homeopathic,

aromatherapy products and herbal medicines. The term ‘complementary medicines’ also

comprises traditional medicines, which includes traditional Chinese medicines, Ayurvedic,

Australian Indigenous and Western herbal medicines.

In response to the Treasurer's general invitation, CMA is pleased to submit its

recommendations for inclusion in the 2018-19 Budget.

Overview

The use of traditional and complementary medicines is growing worldwide, with the global

market expected to reach US$115 billion by 2020.ii Significant growth has been reported in

many countries, including the United States, Canada, across Asia – and in Australia. The

recent Australian complementary medicine industry audit shows that the industry has

generated revenues of $4.7 billion due to increasing interest and demand from consumers,

both in Australia and internationally.

Complementary medicines are an important and culturally acceptable part of healthcare

around the world, representing for many people an accessible, affordable way to actively

contribute to their health.iii The World Health Organization acknowledges that more

countries are coming to realise the contribution that traditional and complementary

medicines (T&CM) can make to the health and wellbeing of individuals and to the

comprehensiveness of their healthcare systems.

“Many countries now recognize the need to develop a cohesive and integrative approach to

health care that allows governments, health care practitioners, and, most importantly, those

who use health care services, to access T&CM in a safe, respectful, cost-efficient and

effective manner.”

(WHO traditional medicine strategy 2014-2023).



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Two significant trends are supporting the growth of the industry in the domestic market: an

ageing population and the challenge of increasing chronic disease; and the growing

awareness of the importance of preventive health. Increasingly, complementary medicines

are being found to contribute to improved health outcomes, through increased

effectiveness, safety and cost-effectiveness, and integration with conventional medical care.

Our export business has doubled in size in just two years, largely due to the growing

popularity of Australia’s high quality products in Asia. The high demand for Australian

natural health products has boosted jobs in the complementary medicines sector across a

range of areas, including manufacturing, scientific evaluation and research. Our industry

holds the ability to continue its positive growth trajectory, increasing highly skilled and

innovation rich local manufacturing, as well as providing a significant contribution to

Australian exports.

CMA believes that the 2018/19 Federal Budget provides an opportunity to:

1. facilitate industry growth and innovation via the implementation of the medicines

and medical devices regulation (MMDR) reforms;

2. focus on preventive health to build a more sustainable health system for Australia;

3. support the growth of our high-quality Australian exports; and

4. encourage and support greater innovation and investment in research.



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1. An Appropriate and Streamlined Regulatory Framework

Recommendation One: Facilitate industry growth and innovation via implementation of the

recommendations made by the Expert Panel Review of Medicines and Medical Devices Regulation

(MMDR) and accepted by Government.

In Australia, the regulation of complementary medicines falls within the remit of the

Therapeutic Goods Administration (TGA), which has the responsibility of regulation of all

therapeutic goods, including medicines and medical devices. The TGA is committed to

contributing to Australia’s health system through best practice regulation of health

products, and safeguarding the health of all Australians through effective, timely and risk

proportionate regulation of therapeutic goods.iv

The Australian regulatory regime for complementary medicines is such that it is viewed by

most countries as the consumer protection benchmark. In comparable countries, such as

the UK, USA and NZ, the standards for similar products are considerably lower, with many

treated as supplemented food, and manufactured and regulated accordingly. Whilst it is

considered by the majority of stakeholders that it is right and proper for complementary

medicines to be regulated by the TGA in Australia, ensuring strict quality and safety

standards for this category of health products, it does mean that over-regulation of these

low-risk products remains the biggest challenge facing the sector.

1.1 Medicines and Medical Devices Regulation Reforms to Reduce Red Tape

CMA has been supportive of the Review of Medicines and Medical Devices Regulation

(MMDR). The main objectives of the MMDR was to improve the timely and safe access to

quality therapeutic goods for consumers, whilst ensuring that any legislative framework is

commensurate with the risk of such goods, and to minimise the regulatory and

administration burden for business. This is consistent with the Australian Government’s

Industry Innovation and Competitiveness Agenda, recognising the need for Australia to

remain competitive on the global stage.

CMA would like to acknowledge the significant work that has been undertaken to date by

the TGA on the MMDR reforms.

1.2 Therapeutic Goods Amendment (2017 Measures No. 1) Bill 2017

The Therapeutic Goods Amendment (2017 Measures No. 1) Bill 2017 builds upon recent

amendments to the Therapeutic Goods Act 1989 to support the continued implementation

of the Government’s response to the MMDR. CMA is supportive of the Bill being passed

through parliament as it implements a range of important MMDR recommendations,



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including a new assessment pathway intended to encourage innovation and protect

investment in research. The Bill also replaces the existing complex complaints system with a

centralised mechanism within the TGA that includes tougher sanctions but decreases

regulatory and administrative burden for businesses.

1.3 New Assessment Pathway to Encourage Investment in R & D

The majority of complementary medicines currently sit within the listed AUST L category on

the Australian Register of Therapeutic Goods (ARTG). One of the MMDR recommendations

is for a new assessment pathway for including a medicine in the ARTG. The intention is for a

business to elect for their product, which contains ingredients already permitted in listed

AUST L medicines, to undergo pre-market assessment of a specific higher level health claim

or claims. This aims to encourage and reward greater investment in research by industry,

and be an incentive to further expand the clinical research base supporting the use of

complementary medicine products.

1.4 Advertising of Therapeutic Goods

The Government has accepted recommendation 55 of the MMDR, that the whole process of

vetting and pre-approval of advertising of therapeutic products to the public should be

stopped in favour of a more self-regulatory regime. CMA has supported the removal of

mandatory pre-approval requirements for several reasons, including reducing unnecessary

complexity for advertisers and to minimise excessive regulatory and financial burden upon

businesses. Implementation of stronger regulator enforcement powers and the

development of a sponsor education programme are expected to manage potential

concerns in implementing the recommendation.

1.5 MMDR Implementation Leading to Increased Regulation

CMA, on behalf of industry, has worked closely with the TGA to facilitate the MMDR

reforms. However, it must be noted that there are a number of areas where the proposed

implementation of the reforms remains a concern as the regulatory burden will increase,

with no foreseeable improvement in consumer protection or access to improved health

products. A number of the changes are not reflective of the aims of the MMDR to decrease

regulatory and administrative burden, and ensure that the legislative framework is

commensurate with the level of risk of therapeutic products. A large number of firms,

especially small and medium enterprises (SMEs) are concerned that the proposed regulatory

framework for complementary medicines will be one of rapidly escalating red tape rather

than the intended risk-proportionate and streamlined regulatory environment. Escalating

regulation is a keenly felt impost, especially when such regulation creates a large

disadvantage for local operators to compete globally.



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1.5.1 Permitted Indications

Work is underway to implement MMDR recommendation 38, which directs the TGA to

establish a list of ‘permitted indications’ from which sponsors must exclusively draw when

listing an AUST L product on the ARTG. The industry is very concerned that the list has

become too restrictive, which will create challenges for firms to continue to market and sell

the current range of products or to develop innovative new products. Removals or

restrictions from the permitted indications list will eliminate products from the listed

medicine space – where this occurs the product sponsor will have to opt for an application

under the new pathway with a $15 600 fee and higher efficacy requirements. This will result

in a regulatory cost to sponsors of preparing and submitting an application for the new

listed assessed pathway for indications that are currently allowed in the listed space.

The significance of the effects upon Australian businesses, particularly smaller and medium

sized entities, cannot be overstated. A number of medicines will not be able to transition to

the new pathway and will lose the ability to make their existing health claims. There is a

significant history of use of these indications on products that have been sold in the listed

space for many years, and no evidence of harm or need for increased regulation.

1.5.2 Removal of Products from TGA Regulation

The regulator has proposed the removal of homeopathic products from TGA regulatory

oversight, which would prevent these products from making any therapeutic claims and

impacts the core viability of manufacturers of these products. These are major decisions

that will affect the business interests of the wider industry and restrict access to these

medicines for consumers who choose to use homeopathic products. In addition to

traditional history of use, there is a growing body of good quality, peer-reviewed research to

demonstrate the effectiveness of homeopathic products as therapeutic goods.

CMA expects that a Regulatory Impact Statement (RIS) would be undertaken when there are

to be significant changes to ingredients or indications, due to the apparent regulatory

impact to businesses. The RIS exemption from the Office of Best Practice Regulation (OBPR)

was based on the deregulatory agenda in relation to the MMDR, noting that the purpose of

the MMDR was to reduce the regulatory burden upon industry and expedite access to

medicines, without compromising safety, quality or efficacy.

Recommendations

Implementation of the MMDR reforms to achieve a risk-proportionate and

streamlined regulatory framework to support industry innovation and growth.

Appropriate evaluation of the regulatory impact of the proposed changes.



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2. Focus on a Sustainable Health System

Recommendation Two: Focus on preventive health to build a more sustainable health system for Australia.

There is a need for increased Government funding for health prevention initiatives to improve the health and wellbeing of the community and create long term savings for the health budget.

Chronic disease is responsible for 83 per cent of all premature deaths in Australia and 66 per

cent of the burden of disease, making it the largest health challenge facing our nation.v Half

of all Australians already have at least one chronic disease, and with an ageing population,

the need to place a stronger focus upon preventive health is becoming increasingly

important.vivii

In 2013–14, only 1.4% of total health expenditure went towards public health activities,

which included prevention and health promotion, much of which was dedicated to

screening and immunisation programs. The proportion of health expenditure allocated to

public health has been declining since it peaked in 2007–08 (2.2%).viii

2.1 Complementary Medicines’ Role in Preventive Heath

There is now robust evidence in a number of areas that complementary medicines are a

cost-effective way to improve health outcomes. Individuals use complementary medicines

as adjunctive therapy to conventional medicines, to help manage chronic disease, prevent

the exacerbation of illness, and to optimise nutrition and wellbeing.

The complementary medicine industry supplies high quality vitamins and minerals that play

a significant role in disease prevention. Nutritional deficiencies have been linked to

increased risk for a number of conditions, including osteoporosis, neural tube defects and

depression.ix The 2011-12 Australian Health Survey identified that:

Nearly three quarters of females (73%) and half of all males (51%) aged two years

and over did not meet their calcium requirements based on their intakes from food.

Females are more likely to have inadequate iron intakes than males, with one in four

(23%) not meeting their requirements compared with one in thirty males (3%).

The 2017 McKell Institute report ‘Picking the low hanging fruit: Achieving a more equitable

and sustainable healthcare system’ finds that targeted evidence-based uptake of certain

complementary medicines would result in notable cost savings in Australia, whilst delivering

better health outcomes and greater equity.x Through addressing some of the social



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determinants of health, which includes having a poor diet, complementary medicines can

play a role in addressing long-term health budget pressures.

Increased uptake of vitamin D and calcium

In Australia, between 31% and 58% of the population is found to suffer from vitamin D

deficiency, despite the fortification of many foods with vitamin D.xi Vitamin D deficiency

has been linked to an increased prevalence of a number of chronic diseases, including

osteoporosis, diabetes and heart disease.xii The McKell Institute estimates that up to 8895

fractures annually could be avoided in Australia with increased uptake of vitamin D and

calcium, saving the Government up to $142 million in direct health costs.

Prenatal Vitamins

Folate, iodine and vitamin B3 are known to prevent neural tube defects. Current Australian

guidelines recommend routine supplementation of folate and iodine, with vitamin D and

iron supplementation for pregnant women with identified deficiencies. Maternal

malnutrition leads to adverse pregnancy outcomes and can lead to the long-term negative

impact upon growth and development during childhood and increases in risk of developing

chronic diseases later in life.

CMA supports the recommendation of increasing the uptake of pregnancy vitamins by low

income mothers to help address health inequalities, estimated by the McKell Institute to

cost between $26 million and $46 million per year, a small cost given the potential benefits

to health equity and long-term savings from stemming the rise in prevalence of chronic

diseases.

Cost effectiveness & Maximising Health Outcomes

There is a growing number of economic analyses that highlight the cost effectiveness of

complementary medicines. A 2014 Frost & Sullivan report, commissioned by ASMI, showed

that several of the more well-known complementary medicines were identified as being

able to reduce the relative risk of experiencing a medical event associated with common

conditions.xiii These include:

Magnesium and calcium/vitamin D combinations for osteoporosis

Lutein and zeaxanthin for age-related macular degeneration

Folic acid/B6/B12 and Omega-3s for cardiovascular disease

St John’s Wort for major depression



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2.2 National Preventive Health Body

CMA supports the call to re-establish a National Preventive Health Body to evaluate

evidence-based interventions at a population level. The best practice example is set by

England, where the National Institute of Health and Care Excellence (NICE) is responsible for

scrutinising the cost-effectiveness of preventive health interventions and monitoring their

outcomes. Re-establishing a preventive health body in Australia would be an important step

towards shifting the health focus from a reactive acute care model to empowering

Australians to take greater responsibility for protecting their health. A fundamental aim of

any health system should be to prevent disease and reduce ill health so that people remain

as healthy as possible for as long as possible.

Preventive health is also an essential move towards improving the cost-effectiveness of the

health care system, by improving Australians’ health and quality of life, reducing

preventable illness and building a more sustainable system for the Australian community. In

the case of complementary medicines, a thoughtful and rigorous strategy, led by the

preventive health body, would further demonstrate the cost-effectiveness and health

benefits of complementary medicines for contributing to the prevention and management

of chronic illnesses and improving public health.

2.3 Complementary Medicines Practitioners and Natural Therapies

Complementary medicine practitioners emphasise nutrition, lifestyle modifications, and the

importance of taking personal responsibility for heath as fundamental principles for

improving quality of life. Natural therapies are recognised by the World Health Organization

and by governments around the world as effective, appropriate and cost-effective solutions

to helping people manage their healthcare. Recent research conducted in Australia

demonstrated that the total number of client consultations is estimated at 16 million

annually, contributing over AUD$1.8 billion to the economy each year.xiv

In Australia, consumers have been increasingly choosing natural therapies as an element of

caring for their health, which is reflected by the complementary and natural therapies

sector outperforming the wider economy. The sector has seen strong growth: according to

IbisWorld (2016) IVA is forecast to grow at a compound annual rate of 4.8% over the 10

years through 2020-21, exceeding the overall economy's forecast real GDP growth of a 2.8%

compound annual growth over the same timeframe. xv

CMA noted the recent announcement of new private health reforms, which include the

cessation of coverage for natural therapies, including herbal medicine, naturopathy, tai chi

and yoga, all of which have a strong evidence base supporting their use to promote good

health. An analysis carried out by PricewaterhouseCoopers found that members across all

levels of hospital cover who also choose ancillary benefits for natural therapies claim $200



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per person less every year in hospital and medical costs; for members with top hospital

cover it was $430 per person less claimed if they chose ancillary benefits for natural

therapies. Ceasing the private health rebate for natural therapies, such as herbal medicine

and naturopathy, should be reconsidered in light of both consumer demand and the

evidence supporting the use of these natural therapies.

Recommendations

CMA supports the development of a strategy, in consultation with physician groups, to increase the uptake of vitamin D supplementation amongst at risk groups, and the introduction of a scheme to provide free vitamins during pregnancy through medical practitioners for women that hold concession cards.

Re-establish a national preventive health body to implement and evaluate population-wide prevention initiatives to improve the health and wellbeing of the community and provide long-term savings for the health budget.



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3. Supporting Growth of Australian Exports

Recommendation Three: Support further growth of our high-quality Australian

complementary medicines exports.

Government support programs are vital to assist Australian exporters to conduct business in

emerging and growth markets, and in terms of provision of advice, capacity building and

expediting export opportunities.

Over 60 per cent of Australian complementary medicine companies are involved in

exporting. The Australian industry has seen the value of complementary medicines exports

double in just 2 years, largely due to the growing popularity of Australia’s high quality

products in Asia. More than half of these exports are destined for China and Hong Kong,

with the top 5 export countries sitting in the Asia-Pacific region.xvi

The Asia-Pacific region is the largest market for complementary medicines products in the

world, and the demand for Australian complementary medicines is expected to remain

strong. Across the region, greater disposable incomes, ageing populations, increased chronic

disease, limited access to primary healthcare, and concerns about food safety and quality

are contributing to the growing demand for Australian complementary medicines.xvii

Chinese consumers’ demand for Australian complementary medicines and health foods has

been well publicised in recent years. The Chinese health food market alone – which includes

vitamins and minerals, herbal extracts and traditional Chinese medicine (TCM) – is currently

valued at US$30 billion and is projected to grow by 10 per cent every year until 2025.xviii The

Chinese Government has also made health a priority in its 13th Five-Year-Plan (2016-2020),

with a number of national initiatives that support demand for complementary medicines,

including adhering to the principle of ‘prevention first’, ensuring food and drug safety and

promotion of TCM.xix

Australian complementary medicines are seen as the benchmark for quality among

international consumers, thanks to Australia’s reputation for quality products and its clean

and well-regulated environment for food and medicines.xx The high demand for Australian

products has boosted jobs in the complementary medicines sector in Australia across a

range of areas, including manufacturing, scientific evaluation and research.

3.1 Support Programs for Exporters

CMA believes that government support programs are vital to assist Australian exporters to

conduct business in emerging and growth markets, and in terms of provision of advice,

capacity building and expediting export opportunities. Maintaining Austrade as a strong



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organisation is vital to Australia’s economy, as are the continued efforts by the Department

of Foreign Affairs and Trade to support Australian firms in building strong international

networks.

3.2 Trade Liberalisation

Continued trade liberalisation will present sizeable opportunities for the Australian

complementary medicines industry as the sector is well positioned to compete for emerging

opportunities. The industry recognises the importance of a strategic, collaborative approach

to International market engagement, leveraging of our strengths and facilitating strong

commercial ties, especially within the Asian region.

CMA also notes and strongly supports the growing focus of Australia’s free trade agreement

negotiations on helping to address ‘behind the border’ issues, and the Australian

Government’s goal of advocating for policy changes beyond other countries’ borders in

support of greater mutual understanding of national arrangements and a better interface

between regulatory frameworks and those of our neighbours.

3.3 Ingredients Grown in Australia

AgriFutures (formerly RIRDC) identifies and nurtures research, innovation and collaborative

efforts to support new and emerging opportunities for rural industries. This includes

support of the emerging Australian seaweed industry, tea tree oil, and native plants such as

wattle seed, Kakadu plum and native pepper. There is currently a large opportunity to

increase the market capacity for Australian grown raw materials for medicinal herbs and for

marine-based ingredients, underpinned by Australia’s ‘clean and green’ branding and

reputation for quality. CMA proposes targeted funding for AgriFutures to work with the

Australian complementary medicines industry, supporting additional research and

commercialisation to fully capture the opportunity of locally grown ingredients.

Recommendations

Maintain current investment in Austrade to support Australian exporters and

enhance Australia’s global competitiveness.

Targeted funding for AgriFutures to collaborate with the Australian complementary

medicines industry to increase locally grown ingredients.

Build on the momentum of the ChAFTA and continue to pursue trade liberalisation

in the Asian region.



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4. Encouraging and supporting innovation and investment in research

Recommendation Four: Encouraging and supporting innovation and investment in research.

Australia holds the potential to be an international leader in complementary medicines

research and translation into both commercial and health policy outcomes.

The complementary medicines industry contributes to employment opportunities and

development of a range of technical and vocational skills through innovation, research and

the utilisation of complex technologies. With the high international demand for Australian

complementary medicines, the sector holds great potential to continue to expand,

contributing further to the strength of our high-skilled local manufacturing. Despite the

positive growth story, the sector in Australia is facing a number of challenges, including the

need to remain globally competitive. Our industry must consistently produce innovative and

value-added products in order to compete internationally.

4.1 Funding for Complementary Medicine Researchers

As recognised by the National Innovation and Science Agenda, Australia has been poor at

translating research into commercial outcomes and ranks low among OECD countries for

measures of commercialisation and business-research collaboration.

Our nation holds the potential to be an international leader in complementary medicines

research and translation into both commercial and health policy outcomes. Australia has

world class academic and research bodies, including two five-star Australian Research

Council recognised institutions, the National Institute of Complementary Medicines and the

Australian Research Centre in Complementary and Integrative Medicine. Australia also

boasts exceptional research centres outside of the university sector, such as the Endeavour

College of Natural Health and the Blackmores Institute.

For every dollar invested in Australian health research and development, $2.17 in health

benefits is returned.xxi Given the potential benefits of complementary medicines as a tool

towards health promotion and disease prevention, complementary medicines research

should be a priority area for funding.

4.2 R&D Tax Incentive

Continued support for innovation in the health care sector is vital to improving productivity

and boosting competitiveness. In the complementary medicines sector, encouraging

business expenditure on research and development will help Australia capture the growing



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market for these products, nationally and internationally, as well as provide significant

economic and health benefits for Australians.

The R&D tax incentive encourages companies to engage in R&D to benefit Australia, and is

important for both supporting SMEs and for attracting multinational firms to invest in R&D

activities in Australia.

Recommendations

Beyond the general need for increased funding support for public health research in

Australia, we suggest that particular areas of research priority include targeted

additional support for complementary medicine research groups.

Maintain the R&D tax incentive in its current form to support R&D activities in

Australia.

Final Word

CMA is also a signatory to and supports the submission made by ARCS on behalf of the

wider medicines and medical technology sector.

CMA appreciates the opportunity to make this submission and feed into the budget process.

Please do not hesitate to contact me should you require additional information or have any

queries in relation to this submission.

Carl Gibson

Chief Executive Officer




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i Complementary Medicines Australia (2017) Healthy People, Healthy Growth. Complementary Medicines Industry Audit 2017. ii Ung, C., Harnett, J. (2017). Community pharmacist’s responsibilities with regards to traditional

medicine/complementary medicine products: A systematic literature review. Research in Social and Administrative Pharmacy 13 686-716 iii Commonwealth of Australia (2017) Complementary Medicines Industry Capability Report.

iv Therapeutic Goods Administration (2017) Therapeutic Goods Administration Business Plan 2017-18

v Jackson H, Shiell A. (2017) Preventive health: How much does Australia spend and is it enough? Canberra:

Foundation for Alcohol Research and Education vi Australian Government. (2015). New stats reveal 50% of Australians battling disease. Accessed from

https://www.health.gov.au/internet/ministers/publishing.nsf/Content/health-mediarel-yr2015-ley100.htm vii

McKell Institute (2017). Picking the Low-Hanging Fruit. Achieving a More Equitable and Sustainable Health Care System. viii

AIHW (2016) Australian Institute of Health and Welfare 2016. Australia’s health 2016. Australia’s health series no. 15. Cat. no. AUS 199. Canberra: AIHW ix Nieves, 2005; Pitkin, 2007; Sarris et al, 2015: Stover, Berry & Filed, 2016, in McKell Institute (2017). Picking

the low-hanging fruit: Achieving a more equitable and sustainable health care system. Equity Economics, Sydney. x McKell Institute (2017). Picking the low-hanging fruit: Achieving a more equitable and sustainable health care

system. Equity Economics, Sydney. xi Boyages, S.C. (2016). Vitamin D testing: new targeted guidelines stem the overtesting tide. MJA 204 (1) doe:

10.5694/mja15.00497 xii

McKell Institute (2017). Picking the low-hanging fruit: Achieving a more equitable and sustainable health care system. Equity Economics, Sydney. xiii

Frost & Sullivan (2014) Targeted Use of Complementary Medicines: Potential Health Care Outcomes & Cost Savings in Australia. xiv

The Practitioner Research and Collaboration Initiative (PRACI) https://praci.com.au xv

IbisWorld. (2016). Alternative Health Therapies in Australia: Market Research Report http://www.ibisworld.com.au/industry/default.aspx?indid=1914 xvi

Austrade (2017) Annual Export Statistics: Vitamins & Supplements. Year ended December 2016 xvii

Commonwealth of Australia (2017) Complementary Medicines Industry Capability Report. xviii

Austrade (2017) Complementary Medicines in China: A guide for Australian business xix

ibid xx

Commonwealth of Australia (2017) Complementary Medicines Industry Capability Report. xxi

Access Economics. (2008). Exceptional Returns: The Value of Investing in Health R&D in Australia.

https://www.health.gov.au/internet/ministers/publishing.nsf/Content/health-mediarel-yr2015-ley100.htm

http://www.ibisworld.com.au/industry/default.aspx?indid=1914

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