From July 2018 to July 2020, complaints about a convenience sample of eighteen complementary medicine hangover products, by eight sponsors, advertised on thirty different Internet sites (cases) were submitted to the TGA. It was alleged that all these advertisements breached the Therapeutic Goods Advertising Code and, as they encouraged excessive alcohol consumption, they represented a serious risk to public health.
Complaint details follow:
- 30 July 2018, BioRevive® Hydrodol® Hangover Relief Products, AC-MW9QQH4F/2018
- 07 August 2018, Multiple Hangover products: Plus Daily Ltd Recoverthol, Clever Health Rejoove, Body Armour Pty Ltd Hangover Relief, D & X Pty Ltd Hey! King Premium Hangover Relief; AC-JY0FXQ3S/2018
- 10 September 2018, Phoenix Pharmaceuticals Rapid Recovery Hangover Relief, AC-EN0KHC4U/2018
- 31 October 2019, Phoenix Pharmaceuticals Rapid Recovery Hangover Relief (again), AC-BGKWMZBG/2019
- 09 July 2020, Newly listed and past hangover product complaints, AC-JJFAKREL/2020.
Followed up on 17 March 2021:
Hangover products are still advertised, despite complaints and lack of evidence. This has occurred even though hangover cures are said to be priority 2 (after COVID-19) on the TGA’s list of advertising compliance priorities. While some products had minor changes made to their claims, the overall impact was minimal.
In addition, extraordinarily little information about these complaints was found by searching their complaint reference numbers in the TGA Advertising Complaints and Investigations Information database. More information was sometimes found in ARTG cancellations requested by the sponsor or in ARTG cancellations by the TGA. All relevant information should be transparently presented in the complaint database to assist consumers to choose products wisely.
More recently the TGA has closed complaints with a statement to the complainant, ‘the information you provided will be used to inform the TGA’s new intelligence led, risk-based compliance approach’. No further public information is provided; there is now even less transparency about how the TGA is handling complaints.
Finally, hangover products are increasingly invoking the TGA’s new permitted indication, ‘Traditionally used in Chinese medicine to helps decrease/reduce/relieve symptoms of occasional hangovers in healthy individuals’. This permitted indication is nonsense and should be disallowed. Allowing traditional permitted indications undermines the scientific evidence base of complementary medicines.
Complaint AC-MW9QQH4F/2018, submitted 30 June 2018
The ARTG listings of all five BioRevive® Hydrodol® Hangover Relief Products complained about were cancelled by the sponsor on 29 Nov 2019, but then relisted with new ARTG numbers. The new products now claim only to support energy production and general health and wellbeing in adults, but they are still packaged as Before and After! See https://hydrodol.com.au/. Meanwhile, hangover claims persist on YouTube videos, e.g., ‘Hydrodol, natural hangover relief, taken while drinking‘ and Facebook.
Complaint AC-JY0FXQ3S/2018, submitted 07 August 2018
ARTG: 296905, Rejoove, Clever Health. No longer listed on ARTG, but still advertised with the same claims (now illegally) at https://rejoove.co/
ARTG: 291026, Recoverthol, Plus Daily Ltd. Still listed on the ARTG and still advertised, albeit with hangover claims and pictures of drink taken off the pack. However, hangover relief claims are still present in testimonials at https://recoverthol.com.au/how-it-works.
ARTG: 306807, Hangover Relief Boon, D & X Pty Ltd (and others). All ARTG listings were cancelled by the sponsor on 23 Mar 2020, but one is still advertised at http://www.dandx.com.au/Hangover-Relief.html. However, this product no longer appears to be sold.
ARTG: 304293, Hangover Relief, Body Armour Pty Ltd. Still listed on the ARTG and still advertised as ‘hangover relief + liver support’ with glowing testimonials at https://www.bodyarmour.com.au/.
Complaint AC-EN0KHC4U/2018 submitted 10 September 2018 and an AC-BGKWMZBG/2018; resubmitted 31 October 2019
ARTG: 297954, Rapid Recovery Hangover Relief, Phoenix Pharmaceuticals. No longer listed on ARTG but still being advertised (illegally) as ‘clinically proven’ by Chemist Warehouse and others.
12 November 2020; email from TGA, ‘case closed. The information you provided will be used to inform the TGA’s new intelligence led, risk-based compliance approach.
22 January 2021, ARTG No:297954 cancelled from the ARTG by the TGA under 30(2) of the Act. However, the sponsor has requested an internal review of this decision.
o9 March 2021, relisted by the sponsor with a new ARTG no: 356374 and new name: Rapid Recovery SOS; not yet being advertised.
Complaint AC-JJFAKREL/2020, submitted 09 July 2020
11 November 2020, the TGA closed the following complaints noting, ‘the information you provided will be used to inform the TGA’s new intelligence led, risk-based compliance approach’. Regardless, their promotion continues.
ARTG ID: 309239, Recovery Enhance, Enervite (Health Spring Australia). Pack still claims, ‘serious help for hangover symptoms’ (not on the ARTG permitted indications), still advertised at https://www.enervite.com.au/product/recovery-enhance/.
ARTG ID: 314758, N+ Hangover Relief, Life Biotech Pty Ltd. Invokes permitted indication, ‘Traditionally used in Chinese medicine to helps decrease/reduce/relieve symptoms of occasional hangovers in healthy individuals’, still advertised at: https://www.mrvitamins.com.au/products/nadvita-9354721000063.
We also have:
ARTG ID: 266432, Drink Smart, Australian Antarctic Ocean Bio-Technology Pty Ltd. Permitted indication: ‘Traditionally used in Asian medicine to decrease/reduce/relieve symptoms associated with occasional overindulgence in healthy individuals’. Advertised at Chemist Direct, etc.
In conclusion, hangover products are still advertised, despite complaints and lack of evidence for their claims. These advertisements breach the Therapeutic Goods Advertising Code, encourage excessive alcohol use and are a serious risk to public health. The TGA should act.
- Therapeutic Goods (Permissible Indications) Determination (No. 1) 2021
- Science or Snake Oil: do hangover cures actually work? (theconversation.com)