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What you may offer: lifestyle analysis or medical genetic analysis
Whether you may offer a genetic analysis depends on its purpose. You can offer lifestyle analyses on nutrition, weight, sport and performance, stress and skin as a partner – within the rules of your country and your profession. Medical analyses belong in a physician’s hands wherever the law requires it: in Germany, only physicians may perform diagnostic genetic examinations (Section 7 GenDG) – Heilpraktiker may not. In Austria, pharmacogenetics is the only medical test the law allows without a physician; whether your profession may offer it is governed by your professional law. Switzerland also regulates lifestyle analyses: only the professions listed in Art. 40 GUMV may order them, and the sample is taken in their presence.
Two catalogs, one clear line
Novogenia offers two kinds of genetic analyses. One covers nutrition, weight, sport and performance, stress and skin. The other covers topics such as predispositions to cardiovascular disease or clotting factors. For the lab, the path is similar: a saliva sample, an analysis, a report. Legally, a clear line separates them. Partners can offer the first group. The second consists of medical genetic analyses – and they are only available through physicians.
What separates the two is not the technology but the purpose. Picture a switch: the same saliva sample can be set to “lifestyle” or to “medicine” – depending on which question the analysis is meant to answer. Once the switch is set to medicine, the physician reservation, information duties and genetic counseling apply. This article shows you where the switch sits in Germany, Austria and Switzerland and what that means for your profession. It gives you orientation but does not replace legal advice in an individual case. You will find the detailed country comparison in the Nutrigenetics guide under Who may offer genetic tests?
Lifestyle or medicine: how to tell the difference
| Question | Lifestyle analysis | Medical analysis |
|---|---|---|
| What it clarifies | how the body processes nutrients, responds to training or handles stress | a disease, a health disorder, a disease risk or the effect of medicines |
| Topics | nutrition, weight, sport and performance, stress, skin | for example cardiovascular predisposition or clotting factors; pharmacogenetics |
| Who offers it | you as a partner, within the rules of your country and profession | wherever the law requires it, only physicians |
| Who interprets it | Novogenia | physicians |
| Sample kit | non-medical device | medical device |
So the question to ask yourself before every analysis is: what is it meant to clarify? “How fast does my body break down caffeine?” is a lifestyle question. “Why is my heart racing?” is a medical one – no matter which genes the lab reads for it.
Germany: physician reservation and the healing arts
The Genetic Diagnostics Act (GenDG) draws the line at the medical purpose. A genetic examination is diagnostic if, among other things, it is meant to clarify an existing disease or health disorder, or whether genetic traits are present that, together with external factors, can trigger a disease or health disorder or can influence the effect of a medicine (Section 3 No. 7 GenDG). Only physicians may perform such examinations, and only specialists in human genetics or suitably qualified physicians may perform predictive ones (Section 7(1) GenDG).
For health professionals without a medical license, a second law applies: the Heilpraktiker Act (HeilprG). Under it, practicing the healing arts (Heilkunde) means any professional or commercial activity to diagnose, cure or alleviate diseases, ailments or physical injuries in humans (Section 1(2) HeilprG). Anyone who wants to do so without being licensed as a physician needs a permit (Section 1(1)); practicing without one is a criminal offense (Section 5 HeilprG). What this means for you:
- Heilpraktiker may practice the healing arts – but may not perform genetic examinations for medical purposes. Use lifestyle analyses as a lifestyle building block, never to investigate symptoms. More in For Heilpraktiker and naturopaths.
- Nutrition consultants, physiotherapists and coaches without a Heilpraktiker permit stay on the lifestyle side twice over: no medical genetic analysis (GenDG) and no diagnosis or treatment of diseases (HeilprG). Anything your profession allows beyond that is governed by your professional law.
- Pharmacogenetics is medical in Germany (Section 3 No. 7(c) GenDG) and belongs in a physician’s hands.
The scope of the GenDG does not list lifestyle analyses without a medical purpose (Section 2(1)). Novogenia’s page Who may perform what? sums it up: genetic analyses without statements on diseases or disease risks may also be offered by nutritionists, fitness trainers or alternative practitioners.
Austria: Gene Technology Act and the physician reservation
The Gene Technology Act (GTG) covers genetic analyses that allow statements about carrier status, a disease risk, an existing disease or the course of a disease or therapy (Section 4 No. 23). Analyses of disease predispositions may only be performed when ordered by a medical specialist (Section 68(1) GTG). Lifestyle analyses that allow none of these statements fall outside this definition.
At least as important for you is the Physicians Act. It counts as medical practice, among other things, examining for diseases, treating them, preventing diseases and prescribing medicines (Section 2(2) Physicians Act 1998). Independent practice of these activities is reserved for physicians (Section 3(1) Physicians Act 1998). For your lifestyle counseling, this means: talk about nutrition, training and well-being – not about preventing diseases.
Pharmacogenetics: in Austria, it is the only medical test the law allows without a physician – partners can offer it there. Whether your profession may do so, however, is governed by your professional law. And prescribing medicines remains a medical task: you do not recommend stopping, switching or re-dosing a medicine but refer your client to the treating physician. Everything about it is in the Pharmacogenetics guide.
The Heilpraktiker profession does not exist in Austria (more in For Heilpraktiker and naturopaths). How the Austrian rules apply to the individual professions is explored in Austria and Switzerland: different rules.
Switzerland: even lifestyle needs the right professional
Switzerland goes one step further. The Federal Act on Human Genetic Testing (GUMG) explicitly regulates genetic analyses outside medicine too, for example of physiological traits whose knowledge can influence a person’s lifestyle (Art. 31(1)). According to the implementing ordinance (GUMV), this means in particular eating habits, physical activity and general well-being (Art. 37(1)). For these analyses:
- Only listed professions may order them: health professionals who are authorized to practice under their own professional responsibility and have acquired knowledge of human genetics (Art. 34(1) GUMG). Art. 40 GUMV lists physicians, pharmacists, psychologists, druggists HF and – for clarifying physiological traits – nutritionists FH, physiotherapists FH, chiropractors and osteopaths.
- Not on the list: health coaches and naturopaths (Naturheilpraktiker). They work with a listed professional who orders the analysis.
- Sample in their presence: the sample is taken in the presence of the person ordering the analysis (Art. 34(3) GUMG). Self-tests are not allowed for these analyses (Art. 13 GUMG).
- Always medical: analyses that provide information in particular on food intolerances, metabolic disorders, an increased risk of sports injuries, or on diseases, allergies and inflammation (Art. 37(2) GUMV).
- Pharmacogenetics is medical. It may be ordered by physicians and, under certain conditions, by dentists, pharmacists and chiropractors (Arts. 5 to 8 GUMV). Nutrition counseling, physiotherapy, coaching and naturopathy are not among them.
Who may do what? The four professions at a glance
| Profession | Germany | Austria | Switzerland |
|---|---|---|---|
| Heilpraktiker / naturopath | lifestyle analyses yes; medical genetic analyses no, despite the Heilpraktiker license (Section 7 GenDG) | the profession may not be practiced | not in Art. 40 GUMV: only together with a listed professional |
| Nutrition counseling and dietetics | lifestyle analyses yes; no healing arts without a permit | lifestyle analyses within your professional law | nutritionists FH may order them (physiological traits) |
| Physiotherapy | lifestyle analyses yes; anything beyond that is governed by your professional law | lifestyle analyses within your professional law | physiotherapists FH may order them; injury risk is medical |
| Health coaching | lifestyle analyses yes; no healing arts, no diagnoses | lifestyle analyses within your trade; do not promise disease prevention | not in Art. 40 GUMV: only together with a listed professional |
Everywhere, the same rule applies: whether your professional title is protected and what it allows you to do is governed by your professional law – genetic analyses do not change that. The details for each profession are in For nutrition consultants and dietitians, For physiotherapists and For health coaches.
The boundary in everyday practice: five warning signs
Whether an analysis stays on the lifestyle side often only becomes clear in the conversation. At these signs, the way leads to a physician:
- Your client has symptoms and hopes the analysis will find their cause.
- Someone wants to know whether they carry a predisposition to a disease.
- Intolerances are to be investigated.
- The conversation turns to medication – stopping, switching, changing the dose.
- A pregnancy, an illness or an eating disorder is involved.
Your words matter too. When a report calls a gene “impaired,” that does not mean “sick.” If you turn a lifestyle result into a disease risk, you shift the purpose – and with it the legal situation. How to explain results cleanly is shown in The consultation: explaining results; what you may say in your advertising in Professional law and advertising: titles, claims.
Frequently asked questions
Can I offer medical genetic tests as a Heilpraktiker in Germany?
When does a lifestyle analysis become medical?
May I offer pharmacogenetics in Austria?
Can I offer lifestyle analyses as a coach in Switzerland?
What do I do if a client comes to me with symptoms?
Related: Who may offer genetic tests? · Pharmacogenetics guide · Who may perform what?
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Request a project →Offer for naturopathsNote: This guide is general information for businesses and professionals and does not replace medical or legal advice. The genetic traits determined in a genetic analysis are well documented (each gene included is backed by at least three independent studies); recommendations derived from them are logical conclusions, not scientifically proven. Regulations can change; errors and changes excepted.
