TGA guidance on health services ads and what counts as advertising

On 21 June 2022 the TGA published guidance on when advertising a health service also advertises therapeutic goods. Much has changed since.

21 June 202211 min read

On 21 June 2022 the Therapeutic Goods Administration (TGA) published three guidance pages that matter to almost every clinic: guidance on advertising health services, guidance on determining whether content is advertising, and guidance on applying the Advertising Code’s rules on price information. Together they explain where promoting your practice ends and advertising a therapeutic good begins.

The TGA does not regulate health services. But if an ad for a health service also promotes a therapeutic good, such as a prescription medicine used in the treatment, the ad must comply with the Therapeutic Goods Act 1989. For cosmetic clinics, weight management services, medicinal cannabis prescribers, compounding pharmacies and vaccination providers, that line decides whether an ad is lawful.

Status update: all three pages have been updated since 2022, some substantially. The health services guidance was amended on 18 December 2023 (medicinal cannabis), 7 March 2024 (cosmetic injectables and indirect references), retitled on 23 September 2024, and heavily revised on 18 June 2026, when it became “Advertising health services that involve therapeutic goods”. The advertising content guidance was rewritten on 7 April 2026. The price information guidance had minor updates in 2023, 2024 and 21 July 2026. We cover the 2024 cosmetic injectables change, the 2026 rewrite of what counts as advertising, and the June 2026 prescription medicines guidance in separate articles. This article explains the framework the 2022 pages set up and how it reads today.

What changed

The TGA’s page histories record 21 June 2022 as the original publication date for all three pages:

Advertising health services (now “Advertising health services that involve therapeutic goods”)
Determining if your content is advertising
Guidance on applying the Advertising Code rules: Price information (now “Applying the Advertising Code rules: Price information”)

They arrived during the transition to the Therapeutic Goods Advertising Code 2021, which commenced on 1 January 2022 with a transition period ending on 30 June 2022, and while the TGA was moving its guidance to a redeveloped website. The TGA said at the time that guidance published during the website transition might not be in its optimal format.

The guidance did not change the law. It explained how the Act’s definition of advertising and the Code apply in a health service setting.

What the TGA said about cosmetic injectables around that time

An archived copy of the TGA’s health services page from September 2022, carrying a “last updated” date of 15 April 2021, shows the approach that applied then. It said you could not refer to prescription-only substances or trade names in ads for cosmetic injection services, including acronyms, nicknames, abbreviations and hashtags. But it listed “acceptable general terms”, including “anti-wrinkle injections” and “dermal fillers”.

That position has since been reversed. On 7 March 2024 the TGA stopped permitting generic terms such as “wrinkle reducing injections” where a reasonable consumer would understand them as promoting a prescription medicine. The current guidance gives an ad promoting “dermal filler treatments” for lips and cheeks as an example of non-compliance, and lists “anti-wrinkle” and “lip injections” as indirect references likely to be prohibited. If your website still uses the 2022-era terms, it needs review.

Who it applies to

The guidance is aimed at any health service whose advertising could also promote therapeutic goods. The current version addresses these services specifically:

cosmetic injection services
medicinal cannabis prescribers
compounding services
vaccination services
services involving biologicals, human cell therapies and platelet-rich plasma
telehealth services.

It is also relevant to GPs, specialists, dentists and allied health practices whenever a service page, social post or campaign mentions a medicine, device or other product used in treatment.

The price information guidance has a narrower audience. Under Part 9 of the Code, only a retail pharmacy, its agent (including a pharmacy marketing group), or a medical practitioner approved under section 92 of the National Health Act 1953 may publish price information about the relevant medicines. The current guidance says all other medical practitioners and health professionals cannot provide that price information to the public.

What the rules require

Advertising is defined broadly

Under section 3 of the Act, advertising includes any statement, pictorial representation or design intended, directly or indirectly, to promote the use or supply of therapeutic goods. The current content guidance explains that intent is judged not by what the person actually intended, but by whether the content “on its face” appears designed or calculated to promote the goods. Each case is assessed on its own facts.

The current guidance lists factors that suggest content is promotional, including a call to action, references to specific goods or classes of goods that create a favourable impression, emotive language or superlatives, emphasising benefits while downplaying risks, information on how to obtain the goods such as price or availability, and content published by someone with a financial interest in the sale of the goods.

All forms of communication count

The current guidance says the definition applies to all media, including websites, emails, blogs, social media posts and user-generated content, product reviews and testimonials, media releases, workshops, webinars, podcasts, shopfronts and signage. It also warns that the names of products, businesses or services can themselves promote therapeutic goods.

Who is responsible

A person can be liable if they advertise or cause the advertising of therapeutic goods. The current guidance says this includes where material is disseminated on their behalf or at their request, or where they control the content, whether or not anyone was paid. It specifically names “a health practitioner or health service” advertising therapeutic goods, or promoting specific goods in promoting its services.

Promoting the service, not the goods

The current health services guidance says a service ad can also advertise goods where it refers to specific therapeutic goods, or a class of goods, used in the service, or represents that patients could obtain a prescription for, purchase, or be treated with those goods through the service. It names substitute terms such as “plant-based medicine”, “wrinkle reducing injections” and “weight loss injections”.

It gives a useful contrast. “Call our clinic for a consultation to discuss treatment options for migraine” does not refer to therapeutic goods. A website promoting the availability of a particular medicine for migraine would likely be advertising that product.

Information given to your own patients

Information a practitioner gives directly to a patient in the course of treating that patient is not subject to the advertising rules. The current guidance says this exception does not apply to publicly accessible content, where there is no established practitioner and patient relationship, or where the minimum standards for a person to be a patient are not met. Mass communications to prospective customers are unlikely to be exempt.

Price information rules

Where Part 9 applies, price information for registered prescription and certain pharmacist-only medicines:

cannot appear on radio or television (including pay and streaming), digital or non-digital displays such as billboards, public transport and mall displays, or in cinema advertising
must be in a list of at least 25 medicines, with the retailer’s name and contact details
must be in alphabetical order by trade name or active ingredient, or grouped by Poisons Standard schedule under set conditions
must not include rewards, embellishments, promotional claims, comparisons, therapeutic uses or photographs that steer consumers to a particular medicine.

The current guidance adds that only prices for registered medicines may be advertised. Price information about ingredients, classes of ingredients or compounded medicines in these schedules must not be advertised.

What it means for your marketing

Website

Your service pages are the main exposure. Describe the consultation, the practitioner and the conditions you assess, not the products used. Avoid brand names, ingredient names, abbreviations, nicknames and class terms for prescription medicines. Check page titles, URLs, image alt text and navigation labels as well as body copy, since all of it forms part of the page.

Google Business Profile and reviews

Business names, service lists and categories on your profile can refer to goods. A profile listing a prescription-only product as a service, or a business name built around one, can promote the goods. Reviews that name a product are also content the TGA treats as capable of being advertising.

Social media and influencers

The June 2026 update added a section on influencers and content creators. It says content showing or implying the use of therapeutic goods, before and after images implying the effect of prescription medicines, and tags, links or discount codes for services involving those goods can all be advertising. It also says responsibility for compliance may extend to both the clinic and the creator.

Paid ads

Search and social ads are short, which tempts advertisers to use the product name as shorthand. Keep ad copy, keywords visible in ads, landing page headings and display URLs free of references to prescription medicines.

Email and SMS

Messages to your existing patient list are still mass communications. The practitioner and patient exception applies to individual treatment advice, not to campaigns.

Printed and in-clinic material

Posters, menus and price boards in a clinic are advertising. A treatment menu that lists prescription-only products or prices for them raises the same problems as a web page.

Common mistakes we see

Using terms that were once listed as acceptable, such as “anti-wrinkle injections” or “dermal fillers”, which the TGA no longer accepts where they would be understood as promoting prescription medicines.
Business names, logos or domain names that refer to a prescription medicine or class of medicine.
Service pages that describe exactly how a prescription product works, including onset and duration of effect.
Price lists for injectable treatments published by clinics that are not entitled to publish price information.
Before and after images that imply the effect of a prescription medicine.
Assuming that adding “speak to your practitioner” makes the content acceptable.
Email campaigns to patients about specific medicines, treated as if they were private advice.

A practical checklist

List every therapeutic good used in each service you promote, and confirm which can lawfully be advertised to the public.
Search your website, profiles and social accounts for brand names, ingredients, abbreviations, nicknames, hashtags and class terms for prescription medicines.
Rewrite service pages around the consultation, the practitioner and the conditions assessed.
Check your business name, logo, domain and profile categories.
Remove or rework before and after images that imply a prescription medicine’s effect.
Remove prices for prescription medicines unless you are entitled to publish them under Part 9, and then follow every Part 9 condition.
Brief influencers and content creators in writing, and review their content before it goes live.
Review email and SMS campaigns for references to specific goods.
Re-check against the current versions of the TGA guidance, not the 2022 text.

How this fits with other rules

The TGA regulates advertising of therapeutic goods. The current health services guidance says an ad for a health service that also advertises a therapeutic good is regulated by the TGA as well.

Ahpra and the National Boards regulate the conduct of registered practitioners, including the advertising of their services. A service ad that avoids every TGA issue must still meet the National Law and Ahpra’s advertising guidelines, including the ban on testimonials. For cosmetic procedures, Ahpra’s separate cosmetic advertising guidelines also apply.

The ACCC administers the Australian Consumer Law, which applies to advertising for health services and related products. State and territory consumer laws may also apply. The TGA’s guidance says advertisers are responsible for complying with all applicable requirements.

Frequently asked questions

Can we say we offer cosmetic injectable treatments?

Be very careful. The current guidance says most cosmetic injectables contain prescription-only substances, and that you must not refer to them even indirectly, including through brand names, acronyms, nicknames or hashtags. Focus on the consultation and the practitioner, and get advice on specific wording.

Is a consultation page for a condition allowed?

Generally, promoting consultations or the conditions a service can treat, without directly or indirectly referring to therapeutic goods, is unlikely to be advertising of therapeutic goods, according to the current guidance.

Can a GP practice publish a price list for prescription medicines?

Only a medical practitioner approved under section 92 of the National Health Act 1953 can, alongside retail pharmacies and their agents, and only in line with Part 9 of the Code.

Can we tell our own patients about a medicine?

A practitioner can give information directly to a patient in the course of treating them. That exception does not cover publicly accessible content or mass communications.

Can vaccination services advertise?

The current guidance says a TGA permission allows approved providers to say they provide vaccines, such as “influenza vaccines”, under conditions that include not naming brands, trade names or ingredients.

Need a hand?

If your service pages were written before 2024, they may still rely on terms the TGA no longer accepts. Our TGA advertising compliance review checks your website, profiles and social content against the current guidance, and our compliant content service rewrites service pages around consultations and conditions. Cosmetic practices may find our cosmetic clinics page useful.

This article is general guidance based on the published rules, not legal advice. Final responsibility for advertising sits with the registered practitioner, and complex situations may need independent legal advice.