The company that sells Nurofen has been fined more than $1 million for misleading consumers about its specific pain products.

The Federal Court previously decided that Reckitt Benckiser, which sells market-leading ibuprofen medication including Nurofen Specific Pain Relief products, had engaged in misleading conduct by advertising that its products were specifically formulated to treat back pain, period pain, migraine pain and tension headaches over four years, when they all had the same active ingredient of ibuprofen lysine.

"None of the four products is any more or less effective than the others in treating any of the particular symptoms," Justice James Edelman said on Friday.

Justice Edelman ordered the company to pay the Commonwealth $1.7 million in the next month. The penalty comes closer to the $1.1 million Reckitt Benckiser had argued it should pay than the ACCC's proposed penalty of $6 million.

Most of the fine - $1.2 million - was for the company's packaging of the products. The company was fined $500,000 for similar misleading representations on its website.

Justice Edelman said that the penalty would have been "far greater" if it were not for a few factors, including that the ACCC had not argued that the company's conduct was intentional or reckless. He also gave the group a discount for co-operating with the ACCC's investigation and admitting to its wrongdoing, which led to other allegations falling away.

The judge said that "the products were effective to treat the pain that they represented so that the only potential effect of the conduct on consumers or competitors was monetary".

A key question was whether Reckitt Benckiser made a profit from advertising the identical products as if they were designed to treat different types of pain.

The ACCC had argued some of the products had been sold at almost double the price of Nurofen's standard range of painkillers.

The Nurofen Specific Pain Range raised about $45 million of the Reckitt Benckiser Group's £8-10 billion global revenue between 2011 and 2015.

Justice Edelman dismissed ACCC's argument that customers would otherwise have opted to buy Nurofen's other standard pain medications.

ACCC's attempt to calculate how much the company profited was a "labour of Hercules...Even with expert evidence it would have been, at best, an extremely rough approximation of profit and, at worst, an informed guess."

However, the judge said the company had intended to profit from its advertising. The judge criticised Reckitt Benckiser for failing to heed "obvious warnings" that it was breaking the law years before the ACCC took legal action, including a Shonky Award in 2010 and a Department of Health order to withdraw its online representations in 2014. Instead "decisions were made to maintain the status quo. (Its) compliance programs failed at basic levels."

ACCC chairman Rod Sims would not rule out appealing the decision to the Full Federal Court, saying the group would consider the judgment carefully.

Mr Sims said the case, which involved millions of products sold across thousands of stores, showed that the maximum $1.1 million penalty for corporations for a single breach of Australian consumer law was "too low" when compared with its $10 million equivalent for a single breach of competition law.

"You've got very large companies here and you've got to ask yourself whether a maximum penalty of $1 million per breach is really sending a large deterrent message for large companies."

ACCC had argued that the company had breached the law six times, rather than twice - once for each of the four products, and twice on its website.

Consumer Affairs Australia and New Zealand is currently reviewing the Australian Consumer law, with a final report due next March.

He noted ACCC had failed to raise a "powerful argument" that to deter the company in future, its overall profit should be considered because its misleading conduct had contributed to it.

A spokeswoman for Nurofen acknowledged the court's decision, saying: "Nurofen did not intend to mislead consumers, however we recognise that we could have done more to assist our consumers...to show that each of the products in the range is equally effective for the other pains indicated on the Nurofen Specific Pain Range packaging."