Chemist Warehouse packaging requirements: supplements, OTC and beauty

How Chemist Warehouse ranges a product

Chemist Warehouse (CWH internally) trades through more than 500 pharmacies under the Chemist Warehouse, My Chemist and ePharmacy brands, and publishes a Supplier Compliance Guideline for anyone who supplies it. The guideline is hosted by its EDI provider, MessageXchange, and it is the document a supplier is held to. Deviations, in its own words, cause delays and unnecessary expense.

Before a single order is placed, the prerequisites are a signed supply agreement, a supplier code issued by CWH, an EDI mailbox set up and tested through MessageXchange, a completed New Line Form for every product, agreed lead times and minimum order quantities, barcoding that meets GS1 standards and access to the MobileDOCK delivery booking system. Most of that is commercial and operational. Two items are the designer's problem: the New Line Form and the barcoding.

The New Line Form

Every product enters through a New Line Form supplied by the buyer. The supplier completes it, the buyer reviews it, and once accepted it goes to Store Operations and Support, who load the line into the product information system and allocate a MyChemID. Only then is the line active and able to be ordered by stores. The form needs pricing, order quantities (outer pack, order multiples, minimum order quantity), lead times, dangerous goods information where relevant, the packaging hierarchy with units of measure, and barcodes for every level. If the artwork is not finished when the form is submitted, the dimensions, weights and GTINs on the form are the ones the retailer will hold the finished pack to.

Product changes: hard and soft

CWH classifies every change as hard or soft, and the classification decides the paperwork. A hard change requires a new New Line Form plus a summary of changes; a soft change needs notice only. Either way the buyer must be told a minimum of 90 days before the change enters the market, and CWH may decline the change.

Read that table as a designer. A rebrand that changes the pack format, the net contents or the consumer-facing declarations is a hard change on three counts and will need a new GTIN as well. A refresh that keeps the format and the declarations and changes the graphics is, at most, a major artwork change: still hard, still buyer approval, still 90 days. Plan the launch date from the retailer's calendar backwards, not from the print date forwards.

Note the price freeze too: a new line carries a 12-month price freeze from launch unless the buyer agrees otherwise, and price changes need the same 90 days notice. A brand owner who plans to launch cheap and raise the price after the first range review is going to wait a year.

Barcodes: the hard requirements

Chemist Warehouse uses GS1 standards throughout and its guideline reads like a condensed GS1 manual. The parts that affect artwork are these.

Unlike Woolworths, CWH accepts UPC-A on retail units, which matters for imported US brands. The retail unit needs one barcode. Inners and cartons need the barcode on a minimum of two adjacent sides, or opposite sides where adjacent sides do not have room. Every barcode must be fully visible on the finished goods: nothing under tape, shrink wrap or strapping, and never only on the base.

Placement on the retail unit

• Do not truncate the bar height. Keep the magnification between the minimum and maximum for the symbology.
• Keep the quiet zones clear of any wording, logos or colour.
• Keep the barcode away from flaps, seams, ripples and undulations, away from the corners of blow-moulded containers, and off the base of the product.
• Place it on a smooth, flat surface. It must not curve around a corner.
• On a round container, run the barcode along the flat edge of the curve in ladder (portrait) orientation.
• GS1 recommends the lower right of the back panel so the location is predictable at the checkout.

Placement and size on cartons

• The lower edge of the bars sits exactly 32 mm above the base of the carton, and the symbol including quiet zones is no closer than 19 mm to either vertical edge.
• Minimum magnification for an ITF-14 or GS1-128 is 50 percent; minimum bar height is 32 mm; 100 percent magnification is recommended.
• An ITF-14 printed directly onto corrugated board should not go below 62.5 percent magnification. Bearer bars are not mandatory but they help print quality on corrugate.
• Bars in matt black on a solid matt white background. Nothing in the red spectrum: scanners use red light and read red bars as background.
• Cylindrical trade units carry the barcode in ladder orientation and are exempt from the 32 mm rule.

Allocating GTINs across the packaging hierarchy

The brand owner allocates the numbers, from a GS1 Australia company prefix. For a carton or inner of identical units the indicator method works: prefix a digit from 1 to 8 to the GTIN-13, recalculate the check digit, and you have a GTIN-14 per packaging level. For a mixed carton you must allocate a new GTIN-13 and lead it with a zero when it goes into an ITF-14 or GS1-128. Deleted GTINs are never reused. And CWH repeats the GS1 allocation rules on when a change needs a new GTIN: a change in quantity of contents (including a promotional bonus pack), a feature change that alters use or presentation, a declared weight change, and a packaging dimension change of more than 20 percent all need a new number. A new label for the same item does not.

What else the carton must say

Human-readable information on inners and cartons must be in English, printed rather than handwritten, and present on at least two adjacent sides at every level of trade packaging:

• The barcode.
• The retail unit description, meaning product, variant and size exactly as printed on the retail unit.
• The supplier part number as printed on the retail unit.
• Batch, serial number and expiry date where applicable.
• Supplier details and/or brand name.
• The quantity of primary units within, stated at each packaging level.
• The total gross weight of the trade item.
• Warning and advisory symbols, and hazardous goods labelling, where applicable.

For anything perishable, which CWH defines to include vitamins, food and infant formula, batch and expiry data are mandatory on the Advance Shipping Notice and the SSCC pallet label, and deliveries can be rejected without them. A GS1-128 carton barcode that encodes GTIN, expiry (AI 17) and batch (AI 10) is the clean way to satisfy both the carton rule and the data rule in one symbol.

Shelf life and date coding: the quiet killer

CWH will only accept stock into its distribution centres and ePharmacy with a minimum of twelve months shelf life remaining; anything shorter needs prior approval from the buyer. When DC stock reaches six months to expiry, supply chain alerts the buyer and the supplier has to agree a clearance plan. Expired stock is quarantined and returned at the supplier's cost.

That is a packaging decision, not just a logistics one. A supplement with a two-year dated life that spends three months in production and a month in transit arrives with twenty months; fine. A product with an eighteen-month life on a slow import schedule arrives at twelve and has no margin. Date coding has to be legible and in a position the DC can read on the carton without opening it, and the pack format should not force a shorter life than the formulation allows. Where the batch and expiry are embossed on clear or translucent packaging, the TGA guidance recommends a darkened background, because embossing on clear material is hard to read.

The TGA rules underneath the retailer rules

For complementary medicines (vitamins, minerals, herbal and nutritional supplements) and OTC medicines, Chemist Warehouse is not the regulator. The Therapeutic Goods Administration is, and a label that fails the TGA standard is not a product the retailer can sell. Three things to know.

ARTG listing and the AUST L number

A listed complementary medicine must be on the Australian Register of Therapeutic Goods, and its AUST L (or AUST L(A)) number must appear on the label. Registered medicines carry an AUST R number. The number can be in a smaller text size than the rest of the mandatory information. Indications on the pack must be drawn from the TGA's permitted indications list for listed medicines, and advisory statements are set by the Required Advisory Statements for Medicine Labels (RASML).

TGO 92 today, TGO 116 from here

The labelling standard for non-prescription medicines has been Therapeutic Goods Order 92. It sunset on 1 October 2026 and was replaced by the Therapeutic Goods (Standard for Labelling of Non-Prescription Medicines) (TGO 116) Order 2026, published on 29 September 2026. Sponsors have a five-year transition: during it a non-prescription medicine may comply with either TGO 92 or TGO 116, and every medicine released for supply after 1 October 2031 must comply with TGO 116. The TGA has said its guidance on TGO 92 remains valid while TGO 116 guidance is written.

The practical consequence for a brand mid-way through a packaging project: design to TGO 92 as it stands, check the TGO 116 text for the elements that will change (the consultation flagged, among other things, writing microgram in full rather than µg, and a safety warning on large solid dose forms), and decide with the sponsor's regulatory adviser whether to adopt the new provisions now. A label that has to change again inside the transition window is a cost the client will remember.

The main label rules that shape the design

• The main label is wherever the medicine name is most conspicuous. A carton and a bottle each have one, and every mandatory main-label item must be oriented the same way.
• The medicine name must be complete, uninterrupted and in one place. Trademarks, graphics and other text must not break up the name, and nothing may interrupt the unit formed by the name and the active ingredients.
• Active ingredient names and quantities stay in a consistent location and presentation across the range.
• Minimum text size for required information is 1.5 mm, measured on the lower-case x-height. Specific items carry larger minimums; the AUST L number is the one exception allowed smaller.
• Colour may differentiate variants within a range, but never as the only differentiator, and colour coding (colour with a fixed meaning) is discouraged unless already established.
• Sentence case is recommended. All-capitals is harder to read and should be reserved for text that RASML mandates in capitals.
• The medicine name on the pack does not have to match the capitalisation of the ARTG entry.

Critical Health Information

Registered non-prescription medicines (most OTC pharmacy lines) must carry Critical Health Information in a tabulated panel: active ingredients, uses, warnings, directions and other information in a fixed order. Listed medicines are not required to use the table but the TGA recommends it, and if you adopt it you must lay it out exactly as the higher-risk medicines do. Absence claims (sugar free, aspirin free) are promotional and do not belong in the CHI table.

Products that are not medicines

Skincare, cosmetics, sunscreens below the therapeutic threshold and many personal care lines are regulated as cosmetics under AICIS and the ACCC's Cosmetics Information Standard, not the TGA. They still have mandatory ingredient listing and the same CWH carton rules. Sunscreens with SPF claims, anti-dandruff shampoos and some acne products are therapeutic goods. If a product sits near that line, settle its classification before artwork starts; it changes the entire back panel.

Cartons, pallets and the DC

Goods ship in new corrugated cartons with no punctures, tears, staples or strapping and all flaps intact; damaged corners are not acceptable. Pallets must be plain 1165 by 1165 mm Australian standard (AS 4068) pallets, not CHEP or Loscam, and any hire pallet delivered becomes CWH property at the supplier's expense. Loaded pallets stay under 1.4 metres high and 1000 kg, with product glued or wrapped, heavy product never on top of light, and a weight icon on cartons where required. One line per pallet where possible rather than one line across many pallets.

Pallets carry a GS1-128 SSCC label to CWH's own specification, with ship-to DC, carrier name and reference, purchase order number and the item GTIN. None of that is artwork, but the carton dimensions and the carton count per layer are, and they are decided when the pack format is decided.

Designing for the Chemist Warehouse shelf

Chemist Warehouse is a dense, price-led, high-sku environment. Shelf tickets are large and yellow, catalogue promotion is constant and the supplement wall runs to hundreds of facings. Three things follow for the pack.

• Front-of-pack hierarchy has to work at two metres: brand, what it is, who it is for, the one number that matters (dose, count, strength). Everything else is for the hand, not the aisle.
• Range architecture matters more than any single pack. A shopper finds the brand block, then the variant. Colour, iconography and a consistent name lockup do that job; they also satisfy the TGA's consistency requirement.
• The catalogue and the website use the same front panel at thumbnail size. If the hierarchy fails at 200 pixels it fails in the catalogue, and the catalogue is where Chemist Warehouse sells.

Natural Animal Solutions, a supplement range the studio rebuilt for pharmacy and pet retail, is the worked example: a strong brand block, one number per pack at hero size, and a back panel built to the regulatory structure rather than squeezed around the marketing.

What gets a product rejected or delayed

• A GTIN that was invented, bought from a reseller or reused from a deleted line. CWH checks against GS1.
• Carton barcodes under 50 percent magnification, under 32 mm high, printed in red or a metallic, or sitting less than 32 mm from the base.
• Only one barcoded side on a carton, or the barcode hidden under tape or wrap.
• A carton with no product description, part number, quantity or gross weight printed on it.
• Stock arriving with less than twelve months to expiry without prior approval.
• Batch and expiry missing from the ASN or SSCC label on a perishable or vitamin line.
• A change to net contents or pack dimensions after the New Line Form, with no new GTIN and no 90 days notice.
• A medicine label that breaks the name-and-active-ingredient unit, uses colour as the only variant cue, or drops the AUST L number.
• Hire pallets, pallets over 1.4 metres, or cartons with crushed corners.

Written by

Morice Kastoun, Founder & Creative Director

Morice Kastoun is the founder and creative director of Morice&Co., an independent Melbourne branding and packaging studio. His packaging has shipped through the compliance processes of Coles, Woolworths, Chemist Warehouse, Priceline, Petbarn, Big W, Myer and Sephora US.