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Guide ยท Advertising rules in plain English

Advertising cosmetic injectables: what the TGA rules mean for clinics

Many dental clinics now offer facial aesthetics. The advertising rules for these services are different from anything else a clinic promotes, because most cosmetic injectables are prescription medicines.

The rule

No reference to prescription medicines.

The TGA does not regulate the advertising of health services. But its guidance explains that an advertisement for a health service can also be an advertisement for a therapeutic good, and prescription medicines cannot be advertised to the public.

The guidance says most cosmetic injectables contain prescription-only substances. So advertising for the service must not refer to them, directly or indirectly. It names brand names, abbreviations, nicknames and hashtags, and its examples show descriptive terms for the products being treated as references too.

In practice

What a clinic can say.

The guidance says that promoting the consultations a clinic offers, without referring to the goods, is unlikely to be advertising a therapeutic good. So the advertising talks about the consultation, the practitioner and the concern the patient wants to discuss.

That applies everywhere: the website, page titles, image captions, social posts, hashtags, ad text and ad keywords. Old posts count as well as new ones.

Ahpra's rules still apply on top. For higher risk cosmetic procedures there are separate Ahpra guidelines, which among other things say practitioners must take steps not to interact with positive reviews of those procedures.

Our approach

How we handle it.

We read every page, post and ad for direct and indirect product references before it goes out, and we go back through older content when we start with a clinic (advertising rule checks).

This page is general information, not legal advice. Ahpra and the TGA publish the rules, and their own guidance is the place to check your situation.

Questions

Common questions.

Can a clinic use the brand name of an injectable in its advertising?

No. The TGA guidance says health service advertising must not refer to prescription medicines, and it names brand names specifically.

Are hashtags covered?

Yes. The guidance lists hashtags among the indirect references to avoid.

What can we advertise instead?

The guidance says promoting the consultations you offer, without referring to the goods, is unlikely to be advertising a therapeutic good.

More

Related guides and services.

Advertising rule checks
All guides

Ahpra advertising rules for dental websites
A plain-English guide to the Ahpra advertising rules that apply to a dental clinic's website, with each point linked to the official source.
Google reviews for dentists
Can a dentist ask for Google reviews, reply to them or share them? A plain-English guide to Ahpra's testimonial rules and Google's review policy.
Before and after photos in dental advertising
When can a dental clinic use before and after photos on its website and social media? A plain-English guide based on Ahpra's advertising guidance.

Next step

Start with a practice check.

Tell us about your clinic and where you think it stands. Your first practice check is free. We reply within one business day, weekends excepted, and we meet every clinic on a video call before any work begins.