Unilever Australasia 219 North Rocks Road North Rocks NSW 2151 Australia Advertising Compliance Unit Regulatory Practice, Education and Compliance Branch Therapeutic Goods Administration PO Box 100 WODEN ACT 2606 Email: [email protected] Dear Sir/Madam, Unilever Australasia is pleased to provide the following comments on the Draft Therapeutic Goods Advertising Code. Unilever Australasia is an international manufacturer and marketer of home and personal care products and is a market leader in many grocery categories in Australia and New Zealand. Our well-known brands include: Domestos, Dove, Jif, Omo, Persil, Rexona, Tresemmé and Vaseline. Our home and personal care products are used every day by millions of people around the world. Consumers trust us to provide them and their families with products that are suitable for use. Although our product portfolio consists largely of consumer goods we do have some products that are regulated as therapeutic goods, even though they are not medicines. Such products are required to comply with the Advertising Code. Unilever support’s Accord’s position that therapeutic sunscreens should not have particular rules assigned to this product type. In particular, secondary therapeutic sunscreens should not require additional statements that are only relevant to primary sunscreens such as the importance of hats, protective clothing and eyewear, regular reapplication and the need to avoid prolonged sun exposure. These products are used on a daily basis for incidental sun exposure, not applied as part of an intentional sun protection regime. Such warnings are not only unnecessary and irrelevant for secondary sunscreens, they are already mandated to be on the label with the introduction of the list of Permitted Indications for Listed Medicines implemented earlier this year. For primary sunscreens, while such statements are relevant to their intended use, the additional messaging within the advertisement provides no real benefit to consumers. Referring consumers to the label, where the statements can already be found, is a more appropriate approach and is covered by the requirement to include the statement: “ALWAYS READ THE LABEL”. Including lengthy warning statements within a 15 to 30 second commercial is not warranted, is unnecessary and should be removed. Given the brevity of these television commercials, such lengthy instructions are more suited to the “directions for use” on a label where consumers have the time to consider and take note of the messaging. It is at the time of application when consumers make decisions about protective sun gear and reapplication, not while they are watching (or reading) an advertisement. Unilever Australasia 219 North Rocks Road North Rocks NSW 2151 Australia We trust these comments are of assistance. Please contact me for further information if required. My email contact details are . Kind regards, Unilever Australasia 27 April 2018 .