Guide for Veterinarians:
Prescribing HempPet® HEMP DROPS™ (CBD)
in Western Australia
Version 2.0 - February 2026
Supersedes Version 1.1 (8 July 2025)
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 WA veterinarians.
1. Key Regulatory Framework (WA) - Updated February 2026
| Level | Instrument | What It Means for CBD Off-Label Use |
|---|---|---|
| Commonwealth (APVMA) |
Agvet Code (Agricultural & Veterinary Chemicals Code Act 1994) APVMA "Cannabis in Veterinary Chemical Products" page (corrected 1 May 2025) |
No CBD veterinary chemical products registered; therapeutic use is off-label. The APVMA removed its erroneous "imported only" restriction on 1 May 2025. Suppliers determine VCP status based on product attributes, properties and claims. Non-therapeutic hemp products (no therapeutic claims) sit outside the VCP system. |
| Commonwealth (ODC / Narcotic Drugs Act) |
Narcotic Drugs Act 1967 (Cth) | Regulates medicinal cannabis for HUMAN use only. Does NOT apply to products manufactured from state-regulated industrial hemp (<1% THC). HEMP DROPS is manufactured under NSW Hemp Industry Act 2008 — ODC has no jurisdiction. |
| WA – Medicines & Poisons |
Medicines and Poisons Act 2014 (WA) Medicines and Poisons Regulations 2016 (WA) |
Vets are expressly authorised to possess, prescribe and supply Schedule 4 CBD (regs 68–70). Must meet Schedule 4 label, storage and record rules. Supply records retained ≥ 2 years. |
| WA – Chemical Use / Off-Label |
Veterinary Chemical Control and Animal Feeding Stuffs Act 1976 (WA) Veterinary Chemical Control of Use Regulations 2006 (WA) |
Only vets may use registered products off-label or unregistered products. Mandatory written statements with dose & withholding period (WHP) kept 3 years. |
| Professional Conduct |
Veterinary Practice Act 2021 (WA) VSBWA Clinical Record-keeping Guidelines |
Requires bona fide Veterinarian–Client–Patient Relationship (VCPR). Clinical records (inc. Schedule 4 supplies & consent forms) held 7 years. |
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 WA 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. WA 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:
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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.
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Contains total cannabinoid content of approximately 2% w/w (predominantly CBD + CBDA), with THC not detected to ≤ 0.1% w/w.
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Composition: 88% hemp seed oil, 2% hydrocarbon hemp concentrate, 10% MCT oil, Vitamin E as stabiliser.
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Meets Poisons Standard Schedule 4 purity requirements (≥ 98% CBD, ≤ 2% other cannabinoids).
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Carries no therapeutic claims on pack - positioned as a nutritional supplement / feed additive.
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Is manufactured under GMP conditions and complies with AS 5812-2017 (Australian Standard for Manufacturing and Marketing of Pet Food).
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Is used therapeutically off-label under a vet's Schedule 4 authority.
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CBD products must not exceed 2% total cannabinoids in WA — 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) + state equivalents |
| 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%) |
| 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 WA - Step by Step
| # | Practical Requirement | Legislative Hook |
|---|---|---|
| 1 | Establish a bona fide Veterinarian–Client–Patient Relationship (VCPR) | Veterinary Practice Act 2021 (WA); VSBWA Guidelines |
| 2 | Conduct clinical assessment and determine therapeutic need for CBD. Document clinical justification in patient records. | Veterinary Practice Act 2021 (WA); AVA Off-Label Prescribing Guidelines |
| 3 | Confirm no registered veterinary alternative exists for the condition/species. | Agvet Code - prescribing cascade; AVA Guidelines |
| 4 | Verify product compliance: review Certificate of Analysis (CoA), confirm ≤ 2% total cannabinoids, confirm industrial hemp source (not ODC cannabis). | Medicines and Poisons Act 2014 (WA) regs 68–70; Poisons Standard Schedule 4 |
| 5 | Obtain informed written consent from owner/agent. Use HEMP PET consent template or practice equivalent. Explain unregistered status, off-label use, benefits, risks, and alternatives. | Veterinary Practice Act 2021 (WA); VSBWA record-keeping guidelines |
| 6 | Prescribe and dispense under Schedule 4 protocols: secure storage, labelling, record-keeping. Retain supply records ≥ 2 years; clinical records 7 years. | Medicines and Poisons Act 2014 (WA); Medicines and Poisons Regulations 2016 (WA) |
| 7 | Monitor patient, document outcomes, adjust dosing as needed. Report any adverse events to APVMA. | Veterinary Practice Act 2021 (WA); APVMA adverse event reporting |
6. Product Compliance Profile - HEMP DROPS
| Regulatory Element | Detail |
|---|---|
| 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 (complies with WA 2% limit) |
| 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 WA 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 competition/racing regulations. Withholding periods may apply under racing authority rules. Document WHP advice to owner. Check with Racing and Wagering WA if applicable. |
| Food-Producing Animals (Livestock) |
Additional obligations under Veterinary Chemical Control and Animal Feeding Stuffs Act 1976 (WA). Mandatory written statement with dose and withholding period, retained 3 years. Residue considerations apply. Consult DPIRD WA guidance. |
9. Clinical Considerations
Current veterinary research and clinical experience support consideration of cannabinoid therapy for:
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Chronic pain management
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Osteoarthritis
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Seizure disorders
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Anxiety and behavioural conditions
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Inflammatory conditions
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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 (WA)
| Record Type | Retention Period | Legislative Basis |
|---|---|---|
| Schedule 4 supply records | ≥ 2 years | Medicines and Poisons Regulations 2016 (WA) |
| Clinical records (inc. consent) | 7 years | Veterinary Practice Act 2021 (WA); VSBWA Guidelines |
| Written statements (livestock) | 3 years | Veterinary Chemical Control of Use Regulations 2006 (WA) |
| Certificates of Analysis | Duration of product shelf life + 2 years (recommended) | Best practice; supports traceability |
11. HempPet® Support for Veterinarians
HempPet® provides the following resources to support WA veterinary professionals:
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Factual composition information only - no therapeutic claims.
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Batch-specific Certificates of Analysis from independent testing.
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Informed consent form templates (see Section 12 below).
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Educational resources through the hemppet.au veterinary portal.
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Continuing Professional Development via Lunch & Learn sessions.
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Regulatory summaries and compliance guidance.
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Technical support: info@HempPet.com.au | 1300 00 HEMP | 0455 889 799.
13. Frequently Asked Questions
Q: Can I prescribe Australian-manufactured hemp-derived CBD products in WA?
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 WA 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 HEMP DROPS comply with WA's 2% total cannabinoid limit?
A: Yes. HEMP DROPS contains approximately 1.3% w/w total cannabinoids, well within the 2% limit.
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.
14. Resources and References
Regulatory Authorities
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APVMA: www.apvma.gov.au
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Office of Drug Control (ODC): www.odc.gov.au
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Therapeutic Goods Administration (TGA): www.tga.gov.au
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DPIRD WA (Veterinary Chemicals): www.dpird.wa.gov.au
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Veterinary Surgeons' Board of WA (VSBWA): www.vsbwa.org.au
Legislation (WA)
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Medicines and Poisons Act 2014 (WA)
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Medicines and Poisons Regulations 2016 (WA)
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Veterinary Chemical Control and Animal Feeding Stuffs Act 1976 (WA)
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Veterinary Chemical Control of Use Regulations 2006 (WA)
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Veterinary Practice Act 2021 (WA)
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Industrial Hemp Act 2004 (WA)
Legislation (Commonwealth)
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Agricultural and Veterinary Chemicals Code Act 1994 (Cth) (Agvet Code)
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Narcotic Drugs Act 1967 (Cth)
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Poisons Standard (SUSMP) – Schedule 4
HempPet® Resources
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Veterinary Portal: hemppet.au
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Retail Website: hemppet.com.au
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Certificates of Analysis: Available through veterinary portal
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Educational Programs: Lunch & Learn sessions for veterinary practices
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Technical Support: info@HempPet.com.au | 1300 00 HEMP | 0455 889 799
— END OF GUIDE —
| Document Version: | 2.0 - February 2026 |
|---|---|
| Supersedes: | Version 1.1 (8 July 2025) |
| Next Review: | As regulatory developments occur or no later than February 2027 |
| Published by: | DECIDE PTY LTD t/a HempPet® — Regulatory Affairs & Veterinary Compliance (WA) |
Disclaimer: This guide provides general information about regulatory frameworks applicable in Western Australia and is not intended as legal or veterinary advice. Veterinarians should consult relevant state legislation, the VSBWA, and professional guidelines when making prescribing decisions. HempPet® provides factual product information only and does not make therapeutic claims. This guide reflects the regulatory position as at February 2026.
For CPD sessions or further support:
info@HempPet.com.au | hemppet.au | 1300 00 HEMP | 0455 889 799