Wholesale Supply and B2B Communication Rules

Wholesale businesses form part of Australia's regulated supply chain for vaping goods, but their ability to exchange product information does not amount to a right to advertise to the public. The relevant authorisation is purpose-specific and audience-specific.

Lawful wholesale supply is the starting point

Sealed wholesale commercial vaporiser kit with certified model identification and barcoding
Wholesale packaged hardware kit designated strictly for authorized commercial distribution channels.

The Therapeutic Goods framework restricts supply and commercial possession of vaping goods. The TGA's advertising guidance allows limited communications exclusively to and between certain businesses engaged in lawful wholesale and retail supply. The underlying supply must be lawful under the relevant regulations; describing someone as a wholesaler does not itself establish eligibility.

What the advertising authorisation permits

For authorised supply-chain recipients, the TGA identifies a constrained range of permitted information, including availability, price, necessary safe-use details and product particulars such as formulation, composition, intended purpose and design specifications. Information must be consistent with the appropriate sponsor notice when required. Testimonials, unsolicited public endorsements and broad promotional messaging should not be treated as part of that limited permission.

Why a trade audience must really be restricted

The phrase “directed exclusively” requires exclusion of other audiences. A wholesale price list presented on a public website cannot rely on an exclusive business-to-business permission merely because the heading says “trade”. The content, actual audience and the applicable recipient categories determine whether the authorisation is relevant.

Recordkeeping and verification

Bona fide participants in a regulated supply chain may need evidence identifying the parties, product class and lawful route of supply. The TGA's sponsor, importer and manufacturer guidance also identifies notification and product-standard obligations. Wholesale businesses should distinguish proof of product compliance from proof that a particular advertising communication is authorised; one does not replace the other.

Frequently asked questions

Can a distributor publicly publish its entire vape catalogue?

The general public advertising prohibition still applies. Limited supply-chain communications require an authorised audience and prescribed conditions.

Can permitted B2B material include any claim?

No. The authorisation restricts the kind of information and promotional features that may be included.

Further reading

Official sources

Information current to 9 October 2026. Australian law and regulatory guidance may change. This page provides general information rather than legal or clinical advice.