Here's the TGA page about sanitisers and COVID-19:...

Here's the TGA page about sanitisers and COVID-19: https://www.tga.gov.au/hand-sanitisers-and-covid-19

If the packaging breaks the "no claims against viruses" rule, then it can't be considered a cosmetic (not regulated by the TGA).

If the product claims to "kill specific organisms (e.g. E.coli or viruses) and/or are to be used in clinics or hospitals", then it is considered a therapeutic good and needs to be registered as an OTC medicine. "Antiseptic hand wash/rub" and "hygienic hand wash/rub" are provided as examples of the latter.

So whether or not the TGA will see NatShield as an unregulated cosmetic or a regulated medicine should be entirely up to management. Or with the way management and marketing has been going, entirely up to the product label designer, or perhaps even the person at the printers making further last minute changes. The labels on the NatShield website have a "Kills more than 150 pathogens included[sic] Coronaviruses" claim, so would probably require TGA regulation.