Summary Comparison Document:

State & Territory Differences for Prescribing
HempPet® HEMP DROPS™ (CBD) in Australia

Version 1.0 – February 2026

Prepared by: HEMP PET Regulatory Affairs

1. Executive Summary

This document provides a consolidated comparison of the key regulatory differences between Australian states and territories that affect the prescribing of HempPet® HEMP DROPS™ (CBD) by veterinary professionals. While the core regulatory framework is consistent nationally — the Poisons Standard (Schedule 4), the APVMA's corrected position (1 May 2025), and the fundamental distinction between ODC-regulated medicinal cannabis and state-regulated industrial hemp — each jurisdiction has its own veterinary practice legislation, poisons legislation, and industrial hemp legislation that creates specific compliance requirements.

The APVMA's removal of its incorrect August 2023 statement on 1 May 2025 applies uniformly across all jurisdictions. The key differences between states relate to: (a) the specific veterinary practice and poisons legislation; (b) record-keeping retention periods; (c) cannabinoid content limits; (d) specific off-label prescribing conditions; and (e) industrial hemp regulatory frameworks.

2. Common National Framework (All Jurisdictions)

The following elements are consistent across ALL Australian states and territories:

Poisons Standard (SUSMP) Schedule 4: CBD is a prescription-only substance nationally. All veterinarians may prescribe S4 substances for animals under their care.
APVMA Correction (1 May 2025): The removal of the incorrect August 2023 statement applies nationally. Australian-manufactured hemp-derived CBD products may be prescribed off-label in all jurisdictions.
Dual Regulatory Framework: The distinction between ODC-regulated medicinal cannabis (Narcotic Drugs Act 1967, human use only) and state-regulated industrial hemp (<1% THC) is consistent nationally. HEMP DROPS falls under the industrial hemp pathway.
Agvet Code: The Agricultural and Veterinary Chemicals Code Act 1994 (Cth) applies nationally. Non-therapeutic products are exempt from VCP registration per the APVMA's post-May 2025 position.
Prescribing Cascade: All jurisdictions recognise the prescribing cascade principle allowing veterinarians to prescribe unregistered products when no suitable registered alternative exists.
VCPR Requirement: A bona fide veterinarian-client-patient relationship is required in all jurisdictions before prescribing.
Informed Consent: Written informed consent from the animal owner is required (or strongly recommended) in all jurisdictions.
Adverse Event Reporting: Reporting to the APVMA Adverse Experience Reporting Program applies nationally.
No Therapeutic Claims: HempPet® makes no therapeutic claims in any jurisdiction. All prescribing decisions are the veterinarian's responsibility.
Product Specification: HEMP DROPS composition (88% hemp seed oil, 2% hemp extract, 10% MCT oil, Vitamin E) and manufacturing (GMP, NSW) are consistent regardless of prescribing jurisdiction.

3. Master Comparison Table - Key Differences by Jurisdiction

3.1 Veterinary Practice & Poisons Legislation

Jurisdiction	Veterinary Practice Act	Poisons/Drugs Act	Veterinary Board	Registration Model
WA	Veterinary Surgeons Act 1960	Medicines and Poisons Act 2014	Veterinary Surgeons Board of WA	NRVR
NSW	Veterinary Practice Act 2003	Poisons and Therapeutic Goods Act 1966	Veterinary Practitioners Board of NSW	NRVR
VIC	Veterinary Practice Act 1997	Drugs, Poisons and Controlled Substances Act 1981	Veterinary Practitioners Registration Board of Victoria	NRVR
QLD	Veterinary Surgeons Act 1936	Medicines and Poisons Act 2019	Veterinary Surgeons Board of Queensland	NRVR
SA	Veterinary Practice Act 2003	Controlled Substances Act 1984	Veterinary Surgeons Board of SA	NRVR
TAS	Veterinary Surgeons Act 1987	Poisons Act 1971	Veterinary Board of Tasmania	NRVR
NT	Veterinarians Act 1994	Medicines, Poisons and Therapeutic Goods Act 2012	Veterinary Board of the NT	AMR (not NRVR)
ACT	Veterinary Practice Act 2018	Medicines, Poisons and Therapeutic Goods Act 2008	ACT Veterinary Practitioners Board	NRVR

3.2 Industrial Hemp Legislation

Jurisdiction	Hemp Legislation	THC Limit (Harvest)	Licence Term	Licence Fees
WA	Industrial Hemp Act 2004	<1%	3 years	Application $368; Renewal $316
NSW	Hemp Industry Act 2008	<1%	Not specified	Application $572; Annual $200
VIC	DPCS (Industrial Hemp) Regs 2018; Agriculture Legislation Amendment Act 2022	<1%	3 years	$500–$1,500
QLD	Drugs Misuse Act 1986 (hemp provisions)	<1%	3 years	Application $506.75; Renewal $202.80
SA	Industrial Hemp Act 2017	<1%	5 years	Application $1,181
TAS	Industrial Hemp Act 2015	<1%	5 years	No fees
NT	Hemp Industry Act 2019	<1%	5 years	Application $1,250
ACT	Hemp Fibre Industry Facilitation Act 2004	<1%	3 years	No fees

3.3 Off-Label Prescribing Conditions & Cannabinoid Limits

Jurisdiction	Cannabinoid Limit	Key Off-Label Conditions	Label Restraint Rules
WA	≤ 2% total cannabinoids	CBD products must not exceed 2% total cannabinoids. Prescribing under Veterinary Surgeons Act 1960. VCPR required.	"DO NOT" restraints apply to all users
NSW	No specific state limit beyond Poisons Standard	No prior NSW Health approval needed for compounded/unregistered CBD. Off-label permitted for non-food species. VPB NSW confirmed alignment 9 May 2025.	"DO NOT" restraints apply only for food-producing animals
VIC	No specific state limit beyond Poisons Standard	Therapeutic need must be established and documented. "All reasonable steps" standard. Animals must be "under care" (real, not nominal).	"DO NOT" restraints apply to all users (including vets)
QLD	≤ 2% total cannabinoids	Must operate from approved premises. Prescriptions limited to animals under direct care. Dispensing limits apply (max 6 months' supply for diversion-risk medicines).	"DO NOT" restraints apply to all users (including vets)
SA	No specific state limit beyond Poisons Standard	Bona fide VCPR mandatory. Examination required before prescribing. Controlled Substances Act 1984 governs S4 supply.	"DO NOT" restraints apply to all users
TAS	No specific state limit beyond Poisons Standard	Off-label use permitted unless explicitly prohibited. Compliance with Code of Practice required. Stringent hemp cultivation licensing.	"DO NOT" restraints apply to all users
NT	No specific territory limit beyond Poisons Standard	Compounded CBD products may be prescribed by NT-registered vets. Hemp Industry Act 2019 permits commercial hemp production.	"DO NOT" restraints apply to all users (including vets)
ACT	No specific territory limit beyond Poisons Standard	Regulations align with federal guidelines. S4 CBD products under veterinary supervision. Personal cannabis use laws do NOT extend to veterinary applications.	"DO NOT" restraints apply to all users

3.4 Record-Keeping Requirements

Jurisdiction	S4 Supply Records	Clinical Records	Livestock Records	Legislative Basis (S4)
WA	≥ 2 years	7 years	2 years	Medicines and Poisons Regulations 2016 (WA)
NSW	≥ 2 years	7 years	2 years (Stock Medicines Act)	Poisons and Therapeutic Goods Regulation 2008 (NSW)
VIC	≥ 3 years	7 years	2 years (Control of Use Act)	DPCS Regulations 2017 (Vic)
QLD	≥ 2 years	5 years	2 years	Medicines and Poisons (Medicines) Regulation 2021 (Qld)
SA	≥ 2 years	7 years	2 years	Controlled Substances (Poisons) Regulations 2011 (SA)
TAS	≥ 2 years	7 years	2 years	Poisons Regulations 2018 (Tas)
NT	≥ 2 years	7 years	2 years	MPTG Regulations 2014 (NT)
ACT	≥ 2 years	7 years	N/A	MPTG Regulation 2008 (ACT)

3.5 Control of Use / Agricultural Chemical Legislation

Jurisdiction	Control of Use Legislation	Agricultural Department	Food-Producing Animal Obligations
WA	Veterinary Chemical Control and Animal Feeding Stuffs Act 1976 (WA)	DPIRD WA	Written directions with dose and WHP required
NSW	Stock Medicines Act 1989; Pesticides Act 1999	NSW DPI	Written directions with dose and WHP required under Stock Medicines Act
VIC	Agricultural and Veterinary Chemicals (Control of Use) Act 1992	Agriculture Victoria (DEECA)	Mandatory written advice with dose and WHP
QLD	Chemical Usage (Agricultural and Veterinary) Control Act 1988	QLD DAF	Written directions required
SA	Agricultural and Veterinary Products (Control of Use) Act 2002	PIRSA	Written directions with dose and WHP required
TAS	Agricultural and Veterinary Chemicals (Control of Use) Act 1995	NRE Tasmania	Written directions required
NT	Agricultural and Veterinary Chemicals (Control of Use) Act 2004	NT DITT	Written directions required
ACT	Environment Protection Act 1997 (limited provisions)	EPSDD ACT	Minimal food-producing animal activity; standard federal requirements

4. Analysis of Key Differences

4.1 Cannabinoid Content Limits

Only WA and QLD have published specific cannabinoid content limits (≤ 2% total cannabinoids) for veterinary CBD products. HEMP DROPS complies with this limit (approximately 1.3% w/w total cannabinoids). All other jurisdictions rely on the Poisons Standard Schedule 4 requirements (≥ 98% CBD, ≤ 2% other cannabinoids) without imposing additional state-level limits.

4.2 Label Restraint Application

A significant difference exists in how "DO NOT" label restraints apply across jurisdictions. In VIC, QLD, and NT, "DO NOT" restraints on product labels apply to ALL users including veterinarians. In NSW, these restraints only apply for food-producing animals. In WA, SA, and TAS, "DO NOT" restraints apply to all users. This distinction is important when considering off-label use of any product with label restraints, though HEMP DROPS carries no such restraints.

4.3 Record-Keeping Retention Periods

Victoria stands out with a longer S4 supply record retention period of ≥ 3 years compared to ≥ 2 years in all other jurisdictions. Queensland has a shorter clinical record retention period of 5 years compared to 7 years in all other jurisdictions. Best practice recommendation: retain all records for a minimum of 7 years regardless of jurisdiction.

4.4 Veterinary Registration Model

The Northern Territory is the only jurisdiction that uses Automatic Mutual Recognition (AMR) rather than the National Recognition of Veterinary Registration (NRVR) model adopted by all other states and territories. Veterinarians visiting the NT from other states should be aware of this distinction. Under AMR, secondary registration is not required for temporary work, but primary registration must be transferred within one month of a change of principal place of residence.

4.5 Therapeutic Need Documentation

Victoria imposes the most stringent requirements around documenting therapeutic need, requiring veterinarians to take "all reasonable steps" to establish therapeutic need before prescribing S4 substances. The VPRBV has published specific guidelines on this requirement. While all jurisdictions require clinical justification, Victoria's standard is the most explicitly articulated. Best practice: apply the Victorian standard in all jurisdictions.

4.6 Dispensing Limits

Queensland imposes specific dispensing limits — no more than 6 months' supply for diversion-risk medicines (which may include CBD products). Other jurisdictions require that the quantity dispensed be "commensurate with therapeutic need" without specifying a maximum supply period. Best practice: dispense quantities appropriate to the treatment plan and review schedule.

4.7 Approved Premises Requirement

Queensland requires veterinarians to operate from approved premises when prescribing and dispensing S4 substances. This is a more specific requirement than in other jurisdictions, which generally require veterinarians to practise from registered or licensed premises without the same level of premises-specific approval.

4.8 Industrial Hemp Licensing Variation

While all jurisdictions permit industrial hemp cultivation under licence, there are significant differences in licence terms (3–5 years), fees (nil to $1,250), and licence types. Tasmania and the ACT charge no fees, while the NT and SA have the highest application fees ($1,250 and $1,181 respectively). These differences primarily affect hemp growers rather than prescribing veterinarians, but are relevant context for understanding the supply chain.

4.9 ACT Personal Cannabis Use

The ACT is unique in permitting personal cannabis use under territory law (since 31 January 2020). However, this does NOT extend to veterinary applications. Hemp products for animals must still comply with federal and territory regulations, including Schedule 4 requirements. Veterinarians in the ACT should not conflate personal use provisions with veterinary prescribing authority.

5. National Compliance Recommendations

Based on the analysis of jurisdictional differences, the following best-practice recommendations apply nationally:

1. Apply the highest standard across all jurisdictions: Use Victoria's "all reasonable steps" standard for documenting therapeutic need, regardless of your jurisdiction.

2. Retain all records for a minimum of 7 years: This exceeds the minimum in all jurisdictions and provides maximum protection.

3. Maintain S4 supply records for ≥ 3 years: This meets Victoria's higher standard and exceeds all other jurisdictions.

4. Obtain written informed consent in all cases: While not explicitly mandated in all jurisdictions, it is best practice and provides legal protection.

5. Verify product compliance before prescribing: Confirm HEMP DROPS is manufactured from industrial hemp (not ODC cannabis), check the CoA, and confirm total cannabinoid content ≤ 2% (meeting WA and QLD limits).

6. Dispense quantities appropriate to the treatment plan: Apply Queensland's 6-month maximum as a national guideline.

7. Report adverse events to the APVMA: This is a national obligation under the Adverse Experience Reporting Program.

8. Stay current with jurisdictional changes: Veterinary practice and poisons legislation is subject to amendment. Check your state/territory veterinary board for updates.

9. For food-producing animals: Apply the most restrictive control-of-use requirements regardless of jurisdiction. Provide written directions with dose and withholding period information.

10. For racing animals: Check with the relevant racing authority in your jurisdiction before prescribing. Withholding periods and detection windows may vary.

6. Quick Reference – Which Guide to Use

Jurisdiction	Guide Document	Key Distinguishing Feature
WA	Guide_Veterinarians_HEMP_DROPS_WA_Feb_2026.pdf	≤ 2% cannabinoid limit; Veterinary Surgeons Act 1960
NSW	Guide_Veterinarians_HEMP_DROPS_NSW_Feb_2026.docx	State of manufacture; VPB NSW confirmed alignment 9 May 2025; No prior Health approval needed
VIC	Guide_Veterinarians_HEMP_DROPS_VIC_Feb_2026.docx	Strictest therapeutic need documentation; 3-year S4 record retention; "all reasonable steps" standard
QLD	Guide_Veterinarians_HEMP_DROPS_QLD_Feb_2026.docx	≤ 2% cannabinoid limit; approved premises requirement; 6-month dispensing limit; 5-year clinical records
SA	Guide_Veterinarians_HEMP_DROPS_SA_Feb_2026.docx	Examination required before prescribing; Controlled Substances Act 1984
TAS	Guide_Veterinarians_HEMP_DROPS_TAS_Feb_2026.docx	Industrial Hemp Act 2015 under review; stringent hemp cultivation licensing; no licence fees
NT	Guide_Veterinarians_HEMP_DROPS_NT_Feb_2026.docx	AMR (not NRVR) for vet registration; Hemp Industry Act 2019 (newest hemp legislation)
ACT	Guide_Veterinarians_HEMP_DROPS_ACT_Feb_2026.docx	Personal cannabis use laws do NOT extend to vet applications; limited hemp cultivation; no licence fees

7. Conclusion

While the core regulatory framework for prescribing HEMP DROPS is consistent nationally — Schedule 4 compliance, the APVMA's corrected position, and the industrial hemp / medicinal cannabis distinction — meaningful differences exist between jurisdictions in the specific legislative instruments, record-keeping requirements, cannabinoid limits, and prescribing conditions. Veterinarians should consult the jurisdiction-specific guide for their state or territory and apply the national best-practice recommendations outlined in Section 5 of this document.

The most significant practical differences are: (a) WA and QLD's explicit ≤ 2% cannabinoid limit; (b) Victoria's stricter therapeutic need documentation and longer S4 record retention; (c) Queensland's approved premises requirement and dispensing limits; (d) the NT's use of AMR rather than NRVR; and (e) the ACT's unique personal cannabis use provisions (which do not extend to veterinary applications).

— END OF SUMMARY DOCUMENT —

Document Version:	1.0 – February 2026
Prepared by:	HempPet® Regulatory Affairs
Classification:	Confidential – For Internal Use and Veterinary Professionals
Related Documents:	Individual state/territory guides (WA, NSW, VIC, QLD, SA, TAS, NT, ACT)