Navigating AHPRA and TGA Advertising Guidelines for Cosmetic Injectable Services

Advertising cosmetic injectable services, such as Botox and dermal fillers, is a complex and highly regulated area in Australia. Registered medical professionals, including doctors, nurses, and dentists, must adhere to strict guidelines set by the Australian Health Practitioner Regulation Agency (AHPRA) and the Therapeutic Goods Administration (TGA). These regulations aim to ensure ethical advertising that prioritises patient safety and informed decision-making.

This article summarises key points from the AHPRA and TGA guidelines. Practitioners are encouraged to review the TGA – Advertising health services and cosmetic injections: frequently asked questions and answers and other resources in full to ensure complete compliance.

AHPRA Guidelines on Advertising Regulated Health Services

The AHPRA guidelines highlight the responsibility of registered health practitioners when promoting cosmetic procedures. These rules apply to various forms of advertising, including websites, social media, and printed materials. Below are the main considerations:

Honesty and Accuracy

• Advertising must provide factual and balanced information, avoiding exaggeration or misleading claims about results.
• Claims must be evidence-based, reflecting realistic outcomes rather than idealised results.

Prohibited Content

• Testimonials or patient stories that endorse clinical outcomes are not allowed, even if shared on third-party platforms.
• Before-and-after images must meet strict criteria, ensuring they are not edited or presented in a misleading manner.

Financial Offers

• Incentives such as discounts, bundled procedures, or gifts that could unduly influence a patient’s decision are prohibited.
• Advertising must include clear and upfront pricing, covering all associated costs, such as anaesthesia and aftercare.

Social Media Conduct

Content posted on platforms like Instagram and Facebook must align with advertising guidelines. This includes any posts by third-party influencers promoting the practitioner’s services.

TGA Guidelines on Advertising Therapeutic Goods

The TGA regulates advertising involving therapeutic goods, including prescription-only medicines used in cosmetic injectables. Practitioners should refer to the TGA – Referring to cosmetic injectables in advertising for specific details. Key requirements include:

Avoiding Product References

• Advertisements must not mention the name of prescription-only medicines, including Botox and dermal fillers, or their ingredients.
• Indirect references, such as “anti-wrinkle injections,” are also discouraged unless presented in the context of a medical consultation.

Focus on Services

Advertisements should promote the health service rather than the specific therapeutic product. For example, practitioners can advertise consultations to assess suitability for wrinkle treatments without mentioning the product used.

Patient Safety

Practitioners must clearly communicate that injectable treatments involve a prescription medicine requiring a consultation with a qualified health professional.

Social Media Restrictions

Hashtags and captions that indirectly refer to prescription-only products or exaggerate results (e.g., #youthfulskin, #instantresults) are prohibited.

Informed Consent and Ethical Considerations

Both AHPRA and TGA guidelines emphasise the importance of informed consent in cosmetic injectables. Practitioners must:

• Provide clear, plain-language explanations of the procedure, risks, benefits, and potential outcomes.
• Avoid language or imagery that glamorises the procedure or trivialises associated risks.
• Ensure patients understand that results can vary based on individual factors such as anatomy and lifestyle.

For more information, visit the AHPRA – Non-surgical cosmetic procedures page.

Specific Prohibitions for Cosmetic Injectables

Restricted Terms

Practitioners must avoid using terms like “magic hands” or “world-renowned” in advertising, as these create unrealistic expectations. Descriptions must remain factual and professional.

Young Audiences

Content should not target individuals under 18, and treatments for this demographic must adhere to stricter guidelines, including psychological assessments and extended cooling-off periods.

Risk and Recovery

Advertisements must provide balanced information on risks, recovery times, and possible complications. Downplaying the invasiveness of procedures or recovery periods is not permitted.

For detailed advice, consult the AHPRA – Fact sheet on injectables.

Best Practices for Compliance

To navigate these regulations successfully, consider the following:

• Regular Training: Ensure that all staff involved in marketing and advertising are trained on the latest AHPRA and TGA guidelines.
• Content Audits: Regularly review advertising materials, including social media posts, to identify and rectify any non-compliant content.
• Legal Advice: Consult legal or regulatory experts to ensure your marketing strategy complies with all relevant laws and guidelines.
• Patient Focus: Prioritise patient safety and informed decision-making in all advertising efforts.

Conclusion

The advertising of cosmetic injectable services in Australia is subject to rigorous scrutiny by AHPRA and the TGA. These guidelines exist to safeguard public health by promoting transparency, honesty, and patient-centred care in advertising practices. Registered medical professionals must stay informed and diligent to ensure compliance while fostering trust and integrity in their practices.

At Derma Institute, we are committed to upholding the highest possible standards of aesthetic training. Our courses are designed to prepare practitioners for cosmetic practice with a focus on patient safety and regulatory compliance. To learn more about our range of training programmes, visit our training courses page.