Guide for Veterinarians:
Prescribing HempPet® HEMP DROPS™ (CBD)
in Queensland
Version 2.0 – February 2026
IMPORTANT REGULATORY UPDATE: On 1 May 2025, the APVMA removed its incorrect August 2023 statement that Australian-manufactured cannabis-derived products could only be prescribed for humans. This guide reflects the corrected regulatory position as at February 2026. Australian-manufactured hemp-derived CBD products may now be prescribed off-label by veterinarians in Queensland.
1. Key Regulatory Framework (QLD) – Updated February 2026
| Level | Instrument | What It Means for CBD Off-Label Use |
|---|---|---|
| Commonwealth | Poisons Standard (SUSMP) – Schedule 4 | CBD is a prescription-only substance. Veterinarians may prescribe S4 substances for animals under their care. |
| Commonwealth | Agvet Code (Agricultural and Veterinary Chemicals Code Act 1994) | Governs registration of veterinary chemical products. Non-therapeutic products exempt from VCP registration per APVMA post-May 2025 position. |
| Commonwealth | Narcotic Drugs Act 1967 | Governs ODC-regulated medicinal cannabis for HUMAN use only. Does NOT apply to state-regulated industrial hemp. |
| State/Territory (QLD) | Veterinary Surgeons Act 1936 (Qld) | Authorises QLD veterinarians to prescribe off-label, including unregistered products, subject to clinical justification and VCPR. |
| State/Territory (QLD) | Medicines and Poisons Act 2019 (Qld) | Implements Poisons Standard in QLD. Authorises veterinarians to obtain, possess, use and supply S4 substances. |
| State/Territory (QLD) | Medicines and Poisons (Medicines) Regulation 2021 (Qld) | Prescribing, dispensing, storage and record-keeping requirements for S4 substances in QLD. |
| State/Territory (QLD) | Drugs Misuse Act 1986 (Qld) (industrial hemp provisions) | Regulates industrial hemp cultivation and supply in QLD. THC limit: <1% (at harvest). |
| State/Territory (QLD) | Chemical Usage (Agricultural and Veterinary) Control Act 1988 (Qld) | Controls use of agricultural and veterinary chemicals in QLD. Additional obligations for food-producing animals. |
2. The APVMA Correction - What Changed and Why It Matters
2.1 The Incorrect Statement (August 2023 - May 2025)
From 4 August 2023, the APVMA's "Cannabis in Veterinary Chemical Products" guidance contained the following erroneous statement:
"In addition to complying with the provisions of Schedule 4 of the Poisons Standard, veterinarians can only prescribe products for therapeutic use in animals that have been manufactured outside of Australia. This is because the law dictates that cannabis-derived products manufactured in Australia are only approved for prescription to people, not animals."
This statement incorrectly conflated two entirely separate regulatory regimes: (a) the Office of Drug Control's jurisdiction over medicinal cannabis under the Narcotic Drugs Act 1967 (restricted to human use); and (b) state/territory-regulated industrial hemp (<1% THC), which is not subject to ODC jurisdiction.
2.2 Removal and Correction (1 May 2025)
On 1 May 2025, the APVMA removed the incorrect statement. The corrected position now provides that "Suppliers determine whether a product is a VCP based on its attributes, properties, and claims." This confirms that non-therapeutic hemp products — including HEMP DROPS — are exempt from VCP registration and may be lawfully supplied to veterinarians for off-label prescribing.
2.3 Significance for QLD Veterinarians
The removal eliminates the only published regulatory guidance that could have been interpreted as prohibiting the veterinary use of Australian-manufactured hemp-derived CBD products. QLD veterinarians may now prescribe HEMP DROPS with confidence that the product's domestic manufacture is not a barrier to lawful off-label use. The Veterinary Practitioners Board of NSW confirmed alignment with the corrected position in writing on 9 May 2025.
3. Scope of This Guide
This guide applies to HempPet® HEMP DROPS™, a manufactured hemp-derived CBD supplement that:
- Is manufactured in NSW from Australian-grown industrial hemp under the Hemp Industry Act 2008 (NSW) and Hemp Industry Regulation 2016 (NSW) — NOT from ODC-regulated medicinal cannabis.
- Contains total cannabinoid content of approximately 2% w/w (predominantly CBD + CBDA), with THC not detected to ≤ 0.1% w/w.
- Composition: 88% hemp seed oil, 2% hydrocarbon hemp concentrate, 10% MCT oil, Vitamin E as stabiliser.
- Meets Poisons Standard Schedule 4 purity requirements (≥ 98% CBD, ≤ 2% other cannabinoids).
- Carries no therapeutic claims on pack — positioned as a nutritional supplement / feed additive.
- Is manufactured under GMP conditions and complies with AS 5812-2017 (Australian Standard for Manufacturing and Marketing of Pet Food).
- Is used therapeutically off-label under a vet's Schedule 4 authority in Queensland.
- Total cannabinoid content must not exceed 2% — HEMP DROPS complies.
Note: Compounded CBD or imported human-use preparations follow separate rules and are not covered by this guide.
4. The Dual Regulatory Framework: Why HEMP DROPS Is Lawful
| Element | Medical Cannabis (ODC) | Industrial Hemp (HEMP DROPS) |
|---|---|---|
| Governing Law | Narcotic Drugs Act 1967 (Cth) | Hemp Industry Act 2008 (NSW) + Drugs Misuse Act 1986 (Qld) (industrial hemp provisions) |
| Regulator | Office of Drug Control (ODC) | State/territory agricultural departments |
| Licensing | ODC licence & permits required | State hemp cultivation licence |
| THC Content | High-THC (therapeutic) | Low-THC (<1% (at harvest)) |
| Permitted Use | Human medical use ONLY | Industrial, nutritional, veterinary (off-label) |
| ODC Restriction | Domestic manufacture restricted to human use | NOT subject to ODC jurisdiction |
KEY POINT: HEMP DROPS is manufactured from state-regulated industrial hemp. The ODC restriction on domestic manufacture for human-only use does not apply. This distinction is the cornerstone of the product's lawful distribution to veterinarians.
5. Off-Label Prescribing Pathway in QLD – Step by Step
| # | Practical Requirement | Legislative Hook |
|---|---|---|
| 1 | Establish bona fide veterinarian-client-patient relationship (VCPR) | Veterinary Surgeons Act 1936 (Qld); AVA Code of Professional Conduct |
| 2 | Confirm no registered veterinary alternative exists for the clinical indication | Prescribing cascade principle; AVA Guidelines |
| 3 | Document clinical justification for off-label CBD use | Veterinary Surgeons Act 1936 (Qld); Veterinary Surgeons Board of Queensland (VSBQ) Guidelines |
| 4 | Obtain informed written consent from animal owner | Veterinary Surgeons Act 1936 (Qld); Professional standards |
| 5 | Verify product compliance: confirm HEMP DROPS is manufactured from industrial hemp (not ODC cannabis), check CoA for batch | Poisons Standard Schedule 4; Hemp Industry Act 2008 (NSW) |
| 6 | Prescribe and dispense under S4 authority; comply with QLD storage, labelling and record-keeping | Medicines and Poisons Act 2019 (Qld); Medicines and Poisons (Medicines) Regulation 2021 (Qld) |
| 7 | Monitor patient outcomes and report adverse events to APVMA | APVMA Adverse Experience Reporting Program; Professional duty of care |
The Medicines and Poisons (Medicines) Regulation 2021 (Schedule 11) authorises Queensland veterinary surgeons to prescribe and dispense Schedule 4 substances for animals under their care. Veterinarians must establish a bona fide VCPR. Prescriptions limited to animals under direct care. Dispensing limits apply (no more than 6 months' supply for diversion-risk medicines like CBD). Veterinarians must operate from approved premises.
6. Product Compliance Profile
| Regulatory Element | Details |
|---|---|
| Source Material | Low-THC industrial hemp (<1% THC), cultivated under NSW state licensing (Hemp Industry Act 2008) |
| Composition | 88% hemp seed oil, 2% industrial hemp extract (CBD ~1.15-1.75% w/w, CBDa ~0.25-0.85% w/w, other cannabinoids <0.01-0.1% w/w), 10% MCT oil, Vitamin E stabiliser |
| Total Cannabinoids | < 2% w/w |
| THC Content | Not detected to ≤ 0.1% w/w (below Sch8/9 thresholds and state industrial hemp limits) |
| Manufacturing | GMP-certified contract manufacturer in NSW; compliant with AS 5812-2017 |
| ODC Jurisdiction | None – product is manufactured from state-regulated industrial hemp, not ODC-licensed medicinal cannabis |
| Product Classification | Non-therapeutic nutritional supplement / feed additive. No therapeutic claims made. Exempt from VCP registration per APVMA post-May 2025 position. |
| Supply Pathway | Exclusive distribution through licensed veterinarians and pharmacies since 2020. Off-label prescribing under QLD veterinary legislation and Schedule 4 compliance. |
7. Supplier & Product Due Diligence Checklist
1. Non-therapeutic declaration - supplier confirms no therapeutic claims are made for the product.
2. Certificate of Analysis (CoA) - batch-specific, confirms ≥ 98% CBD and ≤ 2% other cannabinoids; THC ≤ 0.1% w/w.
3. Australian origin - hemp grown under NSW Hemp Industry Act 2008 (or equivalent interstate industrial hemp licence). Confirm NOT sourced from ODC-regulated medicinal cannabis.
4. Quality assurance - GMP manufacturing and compliance with AS 5812-2017 pet food standard.
5. Batch traceability — batch number, expiry date on pack and invoice.
6. Distribution model — confirm product is supplied exclusively through veterinarians and pharmacies (not direct-to-consumer).
8. Species-Specific Notes
| Species | Extra Obligations |
|---|---|
| Companion Animals (Dogs, Cats) | Standard off-label prescribing pathway applies. No withholding period required. Document clinical justification and informed consent. Monitor for adverse reactions. |
| Horses | Consider Racing Queensland rules. Withholding periods apply under racing authority rules. Check with Racing Queensland if applicable. Document WHP advice to owner. |
| Food-Producing Animals (Livestock) | Additional obligations under Chemical Usage (Agricultural and Veterinary) Control Act 1988 (Qld). Written directions required. Residue considerations apply. Consult Queensland Department of Agriculture and Fisheries (DAF) guidance. |
9. Clinical Considerations
Current veterinary research and clinical experience support consideration of cannabinoid therapy for:
- Chronic pain management
- Osteoarthritis
- Seizure disorders
- Anxiety and behavioural conditions
- Inflammatory conditions
- Palliative care
Note: Veterinarians should evaluate available evidence and apply professional judgment when considering cannabinoid therapy for individual patients. HempPet® does not make therapeutic claims. Prescribing decisions and therapeutic applications are determined solely by the veterinarian's professional judgment.
10. Record-Keeping Requirements (QLD)
| Record Type | Retention Period | Legislative Basis |
|---|---|---|
| Schedule 4 supply records | ≥ 2 years | Medicines and Poisons (Medicines) Regulation 2021 (Qld) |
| Clinical records (inc. consent) | 5 years | Veterinary Surgeons Act 1936 (Qld); VSBQ Guidelines |
| Written statements (livestock) | 2 years | Chemical Usage (Agricultural and Veterinary) Control Act 1988 (Qld) |
| Certificates of Analysis | Duration of product shelf life + 2 years (recommended) | Best practice; supports traceability |
11. QLD-Specific Regulatory Notes
Queensland maintains a 2% total cannabinoid limit which HEMP DROPS complies with (approximately 1.3% w/w total cannabinoids). The VSBQ allows CBD prescribing for therapeutic use provided the total cannabinoid content does not exceed 2%.
12. HempPet® Support for Veterinarians
HempPet® provides the following resources to support QLD veterinary professionals:
- Factual composition information only - no therapeutic claims.
- Batch-specific Certificates of Analysis from independent testing.
- Informed consent form templates.
- Educational resources through the hemppet.au veterinary portal.
- Continuing Professional Development via Lunch & Learn sessions.
- Regulatory summaries and compliance guidance.
- Technical support: info@HempPet.com.au | 1300 00 HEMP | 0455 889 799.
13. Template – CBD Informed Consent Form (QLD)
| Practice: | [Practice Name] |
|---|---|
| Veterinarian: | [Veterinarian Name] |
| Date: | [Date] |
| Owner Name: | [Owner Name] |
| Patient (Animal) Name: | [Animal Name] |
| Species / Breed: | [Species / Breed] |
| Clinical Indication: | [Clinical Indication] |
| Product: | HempPet® HEMP DROPS™ (CBD) |
| Dose / Frequency: | [As prescribed] |
| Review Date: | [Date] |
I acknowledge and consent to the following:
- HEMP DROPS is an unregistered product being prescribed off-label by my veterinarian.
- The product is a hemp-derived CBD nutritional supplement, not a registered veterinary medicine.
- My veterinarian has explained the potential benefits and risks of this treatment.
- I understand that HempPet® makes no therapeutic claims for this product.
- I consent to the off-label use of this product for my animal as described above.
Owner Signature: ________________________ Date: ____________
Veterinarian Signature: ________________________ Date: ____________
14. Frequently Asked Questions
Q: Can I prescribe Australian-manufactured CBD products for animals in QLD?
A: Yes. Following the APVMA's 1 May 2025 correction, there is no restriction on prescribing Australian-manufactured hemp-derived CBD products. HEMP DROPS is manufactured from state-regulated industrial hemp (not ODC medicinal cannabis) and may be prescribed off-label under QLD veterinary legislation, provided Schedule 4 requirements are met.
Q: Do I need ODC approval to prescribe HEMP DROPS?
A: No. The ODC has no jurisdiction over hemp-derived products manufactured from state-regulated industrial hemp. ODC jurisdiction is confined to medicinal cannabis under the Narcotic Drugs Act 1967.
Q: Is HEMP DROPS a registered veterinary chemical product?
A: No. HEMP DROPS is an unregistered nutritional supplement that makes no therapeutic claims. Per the APVMA's post-May 2025 position, it is exempt from VCP registration. Veterinarians prescribe it off-label under the prescribing cascade.
Q: What are my responsibilities when prescribing off-label?
A: You must: (a) establish a bona fide VCPR; (b) document clinical justification; (c) obtain informed written consent; (d) comply with Schedule 4 storage, labelling and record-keeping; (e) monitor patient outcomes; and (f) report adverse events to the APVMA.
Q: Does HempPet® make therapeutic claims?
A: No. HempPet® provides factual composition information only. All prescribing decisions and therapeutic applications are the sole responsibility of the veterinarian.
15. Resources and References
Regulatory Authorities
- APVMA: www.apvma.gov.au
- Office of Drug Control (ODC): www.odc.gov.au
- Therapeutic Goods Administration (TGA): www.tga.gov.au
- Queensland Department of Agriculture and Fisheries (DAF): www.daf.qld.gov.au
- Veterinary Surgeons Board of Queensland (VSBQ): www.vsb.qld.gov.au
Legislation (QLD)
- Medicines and Poisons Act 2019 (Qld)
- Medicines and Poisons (Medicines) Regulation 2021 (Qld)
- Veterinary Surgeons Act 1936 (Qld)
- Drugs Misuse Act 1986 (Qld) (industrial hemp provisions)
- Chemical Usage (Agricultural and Veterinary) Control Act 1988 (Qld)
Legislation (Commonwealth)
- Agricultural and Veterinary Chemicals Code Act 1994 (Cth) (Agvet Code)
- Narcotic Drugs Act 1967 (Cth)
- Poisons Standard (SUSMP) – Schedule 4
HempPet® Resources
- Veterinary Portal: hemppet.au
- Retail Website: hemppet.com.au
- Certificates of Analysis: Available through veterinary portal
- Educational Programs: Lunch & Learn sessions for veterinary practices
- Technical Support: info@HempPet.com.au | 1300 00 HEMP | 0455 889 799
— END OF GUIDE —
| Document Version: | 2.0 – February 2026 |
|---|---|
| Supersedes: | N/A (First edition for this jurisdiction) |
| Prepared by: | HempPet® Regulatory Affairs |
| Classification: | Confidential – For Veterinary Professionals Only |