Guide for Veterinarians:
Prescribing
HempPet® HEMP DROPS™ (CBD)
in Victoria
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 Victoria.
1. Key Regulatory Framework (VIC) - 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 (VIC) | Veterinary Practice Act 1997 (Vic) | Authorises VIC veterinarians to prescribe off-label, including unregistered products, subject to clinical justification and VCPR. |
| State/Territory (VIC) | Drugs, Poisons and Controlled Substances Act 1981 (Vic) | Implements Poisons Standard in VIC. Authorises veterinarians to obtain, possess, use and supply S4 substances. |
| State/Territory (VIC) | Drugs, Poisons and Controlled Substances Regulations 2017 (Vic) | Prescribing, dispensing, storage and record-keeping requirements for S4 substances in VIC. |
| State/Territory (VIC) | Drugs, Poisons and Controlled Substances (Industrial Hemp) Regulations 2018 (Vic) | Regulates industrial hemp cultivation and supply in VIC. THC limit: <1% (at harvest). |
| State/Territory (VIC) | Agricultural and Veterinary Chemicals (Control of Use) Act 1992 (Vic) | Controls use of agricultural and veterinary chemicals in VIC. 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 VIC 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. VIC 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 Victoria.
- Total cannabinoid content must comply with Poisons Standard; no specific state percentage limit published.
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, Poisons and Controlled Substances (Industrial Hemp) Regulations 2018 (Vic) |
| 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 VIC - Step by Step
| # | Practical Requirement | Legislative Hook |
|---|---|---|
| 1 | Establish bona fide veterinarian-client-patient relationship (VCPR) | Veterinary Practice Act 1997 (Vic); 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 Practice Act 1997 (Vic); Veterinary Practitioners Registration Board of Victoria (VPRBV) Guidelines |
| 4 | Obtain informed written consent from animal owner | Veterinary Practice Act 1997 (Vic); 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 VIC storage, labelling and record-keeping | Drugs, Poisons and Controlled Substances Act 1981 (Vic); Drugs, Poisons and Controlled Substances Regulations 2017 (Vic) |
| 7 | Monitor patient outcomes and report adverse events to APVMA | APVMA Adverse Experience Reporting Program; Professional duty of care |
Prescribing permitted under the Drugs, Poisons and Controlled Substances Act 1981. Therapeutic need must be established and documented. Veterinarians must take all reasonable steps to establish therapeutic need before prescribing S4 substances. Victoria requires that animals be "under the care" of the veterinarian, with real (not nominal) oversight.
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 Schedule 8/9 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 VIC 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 Victoria rules. Withholding periods apply under racing authority rules. Check with Racing Victoria if applicable. Document WHP advice to owner. |
| Food-Producing Animals (Livestock) | Additional obligations under Agricultural and Veterinary Chemicals (Control of Use) Act 1992 (Vic). Mandatory written advice with dose and withholding period. Residue considerations apply. Consult Agriculture Victoria (DEECA) 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 (VIC)
| Record Type | Retention Period | Legislative Basis |
|---|---|---|
| Schedule 4 supply records | ≥ 3 years | Drugs, Poisons and Controlled Substances Regulations 2017 (Vic) |
| Clinical records (inc. consent) | 7 years | Veterinary Practice Act 1997 (Vic); VPRBV Guidelines |
| Written statements (livestock) | 2 years (Control of Use Act) | Agricultural and Veterinary Chemicals (Control of Use) Act 1992 (Vic) |
| Certificates of Analysis | Duration of product shelf life + 2 years (recommended) | Best practice; supports traceability |
11. VIC-Specific Regulatory Notes
Victoria maintains strict requirements around establishing therapeutic need and documenting clinical justification. The VPRBV has published guidelines reiterating that veterinarians must establish therapeutic need before prescribing S4 medicines. Denatured hemp seed is permitted in animal feed under the Agricultural and Veterinary Chemicals (Control of Use) Act 1992.
12. HempPet® Support for Veterinarians
HempPet® provides the following resources to support VIC 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 (VIC)
| 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 VIC?
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 VIC 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
- Agriculture Victoria (DEECA): www.agriculture.vic.gov.au
- Veterinary Practitioners Registration Board of Victoria (VPRBV): www.vetboard.vic.gov.au
Legislation (VIC)
- Drugs, Poisons and Controlled Substances Act 1981 (Vic)
- Drugs, Poisons and Controlled Substances Regulations 2017 (Vic)
- Veterinary Practice Act 1997 (Vic)
- Drugs, Poisons and Controlled Substances (Industrial Hemp) Regulations 2018 (Vic)
- Agricultural and Veterinary Chemicals (Control of Use) Act 1992 (Vic)
Legislation (Commonwealth)
- Agricultural and Veterinary Chemicals Code Act 1994 (Cth) (Agvet Code)
- Narcotic Drugs Act 1967 (Cth)
- Poisons Standard (SUSMP) – Schedule 4
HEMP PET 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 |