TGA social media advertising guide: influencers and testimonials

The TGA’s first social media advertising guide, published 31 March 2022, set the rules for posts, comments and influencer testimonials.

31 March 202210 min read

On 31 March 2022 the Therapeutic Goods Administration (TGA) published its social media advertising guide. It set out, in one place, how the Therapeutic Goods Act 1989 and the Therapeutic Goods Advertising Code apply to posts, comments, hashtags and influencer content about therapeutic goods.

The timing mattered. The new 2021 Advertising Code had commenced on 1 January 2022, with its tighter wording on paid testimonials and practitioner endorsements, and the transition period was due to end on 30 June 2022. For clinics using Instagram, Facebook or TikTok to promote products, or working with influencers, the guide made clear that social media is not a grey zone.

Status update: this guide has since changed. On 23 September 2024 it was retitled “Advertising therapeutic goods on social media” as part of a website migration, and on 5 November 2025 the TGA substantially updated it with much more detail on links, hashtags, sharing, livestreams, podcasts, AI-generated content and historical posts. We cover the 2025 version in our article on the TGA’s updated social media advertising guidance. This article explains the original 2022 guide and the rules it relied on.

What changed

The 2022 guide did not create new law. It explained how existing law applies to social media. Its central message was simple: “A social media post that promotes the use or supply of therapeutic goods is an advertisement.” Whether an ad appears on social media or anywhere else, it must comply with therapeutic goods legislation.

The archived version of the page carried a note dated 25 March 2022 saying the page would soon be updated to reflect the requirements of the 2021 Code. Its substance, however, already referred to the 2021 Code’s structure, including Part 6, section 24 on testimonials and Part 9 on price information.

The guide covered:

what therapeutic goods are, and how ordinary products can become therapeutic goods when therapeutic claims are made about them
the broad definition of advertising
basic advertising rules under the Act and Code
business owner responsibilities, including for third-party comments
specific requirements for social media ads, including mandatory statements and testimonials
tips for social media influencers.

Who it applies to

The guide was written for advertisers of therapeutic goods on social media platforms. In practice, that includes:

medical, dental, allied health and cosmetic clinics that post about products they sell, use or recommend
pharmacies and online retailers
product brands and their social media teams
influencers who have been paid or given products to promote goods
agencies and freelancers who manage social media accounts for any of the above.

It also reached products that are not usually thought of as therapeutic goods. The guide noted that claims such as “removes toxins”, “fades age spots”, “relieves pain” or “reduces inflammation in the body” are therapeutic use claims. If those claims are made in an ad, the product is likely to be treated as a therapeutic good and regulated accordingly. That is a real risk for skincare and wellness products promoted by clinics.

What the rules require

The broad definition of advertising

The guide restated that any statement, pictorial representation or design intended, directly or indirectly, to promote the use or supply of therapeutic goods is an advertisement. It also noted that not all information about therapeutic goods is advertising, but the definition is broad.

Basic advertising rules

The guide summarised the rules that an ad must meet, including that it must:

be accurate, balanced and substantiated (Part 3 of the Code)
only make claims consistent with the product’s indication or intended purpose as recorded on the Australian Register of Therapeutic Goods (ARTG)
contain the relevant mandatory warning statements (Part 4 of the Code)
only use testimonials that comply with all applicable parts of the Code, not just section 24
not claim a product can diagnose, treat or cure a serious condition without prior TGA permission or approval.

It also reminded readers that prescription medicines and certain pharmacist-only medicines are prohibited from being advertised directly to the public, with price advertising allowed only under the conditions in Part 9 of the Code.

Responsibility for your pages and comments

This was the part of the guide with the most direct effect on clinics. It said business owners are responsible for the content of any social media page created or managed by them, including websites, social media channels, blog posts, hashtags or discussion forums. That responsibility “extends to user-generated content”, such as third-party comments on platforms controlled by the business.

In other words, if a follower comments on your clinic’s post with a glowing account of a product, and the comment would breach the Code, it is your problem to deal with.

Mandatory statements must stay visible

The guide said social media ads must include the relevant mandatory statements and health warnings where applicable, and that health warnings must be prominently displayed or communicated at the point of purchase, including purchases through social media. Importantly, it said mandatory statements and health warnings “must be visible at all times” and not within collapsed information, because collapsed text does not meet the requirement to be prominently displayed or communicated.

That rules out burying the statement below a “more” link in a caption.

Testimonials and endorsements

The guide said ads must comply with Part 6 of the Code and listed key points:

ads cannot include testimonials from a person who has received “valuable consideration” for making them
valuable consideration is payment of some value, such as money or free product
ads cannot contain testimonials and endorsements by health professionals and others listed in Part 6.

Acceptable use policy and corrective information

The TGA recommended that businesses adopt an “acceptable use policy” on their own social media pages, warning third parties that non-compliant comments will be removed. It also recommended that businesses provide corrective information if they become aware of misinformation from third parties on channels they are not responsible for, while making sure any corrective information also complies with the advertising rules if it is, or is used within, an advertisement.

Tips for influencers

The guide addressed influencers who are involved with a business selling or promoting therapeutic goods, for example because they have been paid or given product. It said:

any post an influencer makes about a therapeutic good may be advertising, and if so the influencer must comply
comments about personal experience with the goods amount to a testimonial, which is not permitted from those involved in production, sale, supply or marketing, including engaged influencers and anyone who receives valuable consideration
therapeutic goods should be chosen on the basis of clinical need, not through the persuasion of influencers
influencers should understand the product’s approved purpose and not promote it for anything else, even if their own experience differs.

What it means for your marketing

Social media posts

Treat every post about a product as a potential advertisement. Before posting, check the claims against the ARTG entry, check that any mandatory statement is in the visible part of the post, and check there is no testimonial or endorsement that the Code prohibits. For registered practitioners, remember that Ahpra’s rules apply to the services side of the same post.

Comments and community management

Monitor comments on your clinic’s pages. Remove comments that make claims about products the Code would not allow, such as claims about serious conditions or uses outside the approved purpose. Publish an acceptable use policy on the page, in the About section or equivalent, so followers know non-compliant comments will be removed.

Influencers and gifted product

If you give an influencer free product or pay them to talk about a therapeutic good, their personal experience posts are testimonials from someone who received valuable consideration. Under the 2021 Code those are not allowed in advertising about the goods. Sharing or reposting them on your own channels makes them part of your advertising.

Practitioners on camera

A clinic doctor, nurse or other health practitioner should not be shown endorsing a therapeutic good. The 2021 Code extends this to former health practitioners, which matters for content creators who once worked in healthcare.

Social shopping and product links

If customers can buy a product through a social post or shop, the post is at the point of purchase. Health warnings need to be prominently displayed there, and not tucked inside collapsed text.

Prescription medicines

None of this creates a pathway for promoting prescription medicines on social media. They cannot be advertised to the public.

Common mistakes we see

Putting mandatory statements at the end of a long caption where they are hidden behind “more”.
Reposting a customer’s or influencer’s story about a product without checking whether it is a testimonial the Code allows.
Gifting product in exchange for “honest reviews” and then featuring those reviews.
Leaving comments that claim a product helped with a serious condition sitting under a clinic post.
Making therapeutic claims about skincare that turn it into a therapeutic good without realising.
Having the clinic’s practitioners hold, apply or recommend a product on camera.
Assuming a private group or story that disappears is not advertising.

A practical checklist

List every product your practice mentions on social media and check its ARTG entry and approved purpose.
Check each post for claims outside that purpose and for references to serious conditions.
Place any required mandatory statement in the visible part of the post or graphic.
Remove testimonials from paid or gifted influencers, staff and anyone else who received valuable consideration.
Remove any practitioner endorsement, including by former practitioners.
Publish an acceptable use policy on each clinic page.
Set a regular schedule to review and moderate comments.
Brief any influencer or content creator in writing on the TGA and Ahpra rules before they post.
Check that no post refers to a prescription-only medicine, directly or indirectly.
Review older posts as well as new ones.

How this fits with other rules

Ahpra and the National Law. If you are a registered practitioner, Ahpra’s social media guidance and the Guidelines for advertising a regulated health service apply to your service advertising on social media. Using testimonials in advertising a regulated health service breaches the National Law, which is stricter than the Code’s position on genuine unpaid product testimonials.

The Australian Consumer Law. The ACCC expects influencer relationships to be disclosed and reviews not to be manipulated. For therapeutic goods, the Code goes further: a paid testimonial is not allowed even if it is disclosed.

Platform rules. Social platforms have their own policies on health products. Those are separate from the law and do not replace it.

Frequently asked questions

Are we responsible for comments other people leave on our posts?

The 2022 guide said a business’s responsibility extends to user-generated content, such as third-party comments on platforms it controls. The 2025 update says this responsibility may extend to third-party comments and treats reviews and comments claiming use of goods as testimonials.

Is a free product “valuable consideration”?

Yes. The 2022 guide described valuable consideration as payment of some value, such as money or free product.

Can we put the mandatory statement in the comments or behind “see more”?

The 2022 guide said statements must be visible at all times and not within collapsed information. Put them where the viewer will see them without clicking.

Can an influencer who used to be a nurse endorse a product for us?

No. The 2021 Code prohibits endorsements by current or former health practitioners and health professionals.

Does the guide still apply?

The current version, last updated on 5 November 2025, has replaced the 2022 text. The core principles described here carried through, with considerably more detail added.

Need a hand?

If your clinic posts about products or works with influencers, our social media for clinics service builds compliance checks into planning and moderation. For a one-off review of your existing feed and comments against both TGA and Ahpra rules, see our TGA advertising compliance service.

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.