On 7 March 2024 the Therapeutic Goods Administration (TGA) updated its guidance on advertising cosmetic injectables. Until then, the TGA had tolerated generic, non-product terms such as “wrinkle reducing injections” when clinics promoted their cosmetic services. From 7 March 2024 it no longer permits those terms where a reasonable consumer would understand the content is meant to promote the use or supply of a prescription medicine.
For cosmetic clinics, cosmetic nurses, doctors and dentists who offer injectables, this was a significant shift in day-to-day marketing. Service menus, website headings, social captions, hashtags, booking pages and price lists that had relied on generic wording all needed review. The TGA was clear that the law itself had not changed: what changed was how it would interpret indirect references.
Later updates: the TGA’s position has since been restated and expanded. On 18 June 2026 the TGA substantially updated its health services guidance (now titled “Advertising health services that involve therapeutic goods”) and published new guidance, “Complying with the restrictions on advertising prescription medicines to the public”. That newer guidance lists “wrinkle reduction injections” as an example of an indirect reference to a class of prescription medicines. Separately, Ahpra and the National Boards’ guidelines for advertising higher risk non-surgical cosmetic procedures took effect on 2 September 2025. See our articles on the June 2026 TGA prescription medicines guidance and on the Ahpra non-surgical cosmetic advertising guidelines for the current detail.
What changed
The TGA announced the change in a media release titled “Referring to cosmetic injectables in advertising”, published 7 March 2024. It explained the history and the reason for the shift.
The old approach
Historically, the TGA allowed indirect references to prescription medicines in advertisements for cosmetic health services, but only in the context of promoting the service and only by using generic, non-product terms such as “wrinkle reducing injections”. Express references to the products or ingredients themselves, such as a brand name or “botulinum toxin”, were never permitted. The TGA described this as a pragmatic approach that let clinics offering these services differentiate themselves from clinics that did not.
Why the TGA changed its position
The TGA said it had observed clinics and health services in other industries advertising the availability of prescription medicines by referring to a class of goods, giving the examples “weight loss injections”, “medicinal cannabis” and “nicotine vaping products”. It interpreted that kind of service promotion as an advertisement for a therapeutic good that refers to prescription medicines, which is unlawful.
Allowing generic class terms for cosmetic injectables while treating similar terms as unlawful in other sectors was inconsistent. To resolve that inconsistency, the TGA stopped permitting terms like “wrinkle reducing injections” where they would lead a reasonable consumer to understand that the content is intended to promote the use or supply of a prescription medicine.
What the TGA said had not changed
The release stressed that the legislation regarding cosmetic injectables had not changed. Advertising the use or supply of prescription medicines, including most cosmetic injectable products (as opposed to services), has never been compliant with the therapeutic goods framework. The TGA specifically listed testimonials, claims about the goods, before and after photos, and price lists as ways this kind of unlawful advertising occurs.
How the TGA said it would respond
The TGA said it would seek high levels of voluntary compliance by engaging with and educating industry first, and would run industry information sessions in the following months. It also said it expected industry to take prompt steps to review existing advertising of cosmetic injectables and bring it into line with the new guidance. Any future compliance action would be evidence-based and would adjust to the nature and seriousness of the alleged non-compliance.
The TGA also linked the update to the focus of other regulators on health professionals performing non-surgical cosmetic procedures, and to what it called the increasing vulnerability of Australians influenced by advertising in the cosmetic space. It noted that prescription-only medicines carry higher risks than goods available for self-selection, and that decisions about treatments involving prescription medicines should be made by a health professional in consultation with each patient.
Who it applies to
The rule applies to anyone who advertises a cosmetic service in a way that refers, directly or indirectly, to a prescription medicine. In practice that includes:
- cosmetic clinics and medispas
- cosmetic nurses, doctors and dentists who offer injectable treatments
- plastic and cosmetic surgery practices that also offer non-surgical services
- influencers and content creators who promote clinics or injectors
- agencies, freelancers and staff who write or post content on a clinic’s behalf
The TGA’s rules attach to the advertising, not only to the registered practitioner. Anyone who advertises, or causes the advertising of, therapeutic goods can be responsible.
What the rules require
No generic terms that point to a prescription medicine
Terms such as “wrinkle reducing injections” are no longer acceptable where a reasonable consumer would read them as promoting a prescription medicine. The test is about how the content is understood in context, not whether a product name appears. The same logic applies to colloquial and shorthand terms that consumers commonly associate with prescription injectables.
No product or ingredient names
Express references to products or ingredients, such as brand names or “botulinum toxin”, were never permitted in public advertising for cosmetic services, and that remains the case. The TGA’s current health services guidance says that when advertising a cosmetic service, you must not refer to prescription medicines or substances, even indirectly, including brand names, acronyms or abbreviations, colloquial names or nicknames, and hashtags that may be taken as a reference to a specific prescription-only medicine or substance.
No testimonials, claims, before and after photos or price lists for prescription injectables
The TGA said advertising the use or supply of prescription cosmetic injectables through testimonials, claims about the goods, before and after photos or price lists has never been compliant. These formats are where many clinics had been relying on generic wording, so they deserve particular attention.
Dermal fillers are treated as prescription medicines
The current health services guidance includes an example advertisement for “dermal filler treatments” to reduce wrinkles and add volume to lips and cheeks. The TGA says it is non-compliant because lip and cheek fillers are prescription medicines and cannot be advertised to the public. The guidance also says the restriction does not apply to cosmetic injectables that do not contain prescription-only substances, although those advertisements must still comply with the Advertising Code and other requirements.
Promote the service, not the product
The TGA’s general guide in the health services guidance is that promoting the type of practitioner consultation offered, or the conditions a service can treat, without directly or indirectly referring to therapeutic goods, is unlikely to be advertising of therapeutic goods. Its own example is a consultation to discuss treatment options for migraine.
What it means for your marketing
Website
Your website is usually where generic injectable terms are most deeply embedded: navigation labels, page titles, URLs, headings, meta titles and descriptions, image alt text and FAQs. Review every page that describes injectable services. Replace product-led or class-led wording with wording about the consultation, the practitioner and the concerns patients can discuss. Treatment pages that read as a menu of injectable products are likely to need restructuring rather than light editing.
Check SEO elements too. A page that avoids the term in the body copy but keeps it in the page title, URL slug or meta description is still publishing that term.
Google Business Profile and reviews
Business descriptions, service lists, product listings, posts and photo captions on your Google Business Profile are all public advertising. Remove injectable product terms, generic class terms and treatment price lists from those fields. Do not repost or highlight patient reviews that describe prescription injectables; Ahpra also prohibits testimonials in advertising for regulated health services, so reviews need care for more than one reason.
Social media and influencers
Captions, hashtags, story text, highlight titles and handles can all carry indirect references. Hashtags are expressly called out in the TGA’s guidance. Before and after content suggesting results came from a prescription injectable is a clear risk. If you work with influencers, brief them in writing that they must not use injectable product names, nicknames or class terms, and must not post results or discount codes for prescription injectable treatments.
Paid ads
Search and social ads are short, which tempts advertisers to use the shorthand consumers search for. Keyword lists, ad headlines, sitelinks and landing page headings all need to avoid product names and generic prescription injectable terms. Build campaigns around consultations and the practitioner’s service instead.
Email and SMS
Promotional emails and texts to your patient list are public-facing marketing for this purpose. Do not send offers, specials or price promotions for prescription injectable treatments. A message inviting existing patients to book a review consultation is a different proposition from a message promoting a named or implied injectable product.
Printed and in-clinic material
Window signage, waiting room posters, brochures, menus and price boards are advertising. Price lists for prescription injectables were specifically named by the TGA as non-compliant. Review anything a member of the public can see or take away.
What you can still promote
None of this stops a cosmetic clinic marketing itself well. The focus moves from the product to the practice and the consultation. Approaches that work within the rules include:
- promoting consultations, assessments and treatment planning with a qualified practitioner
- explaining your practitioners’ training, registration and approach to safety
- describing the consultation process, including how suitability is assessed and how risks are discussed
- educational content about skin, ageing and general approaches to treatment, written without promoting a prescription medicine
- practical information about your clinic, location, hours and how to book a consultation
From 2 September 2025, the guidelines for advertising higher risk non-surgical cosmetic procedures also apply on top of the TGA rules. Among other things, they restrict targeting people under 18, idealised or sexualised imagery and testimonials, and they expect advertising to be honest about risks and recovery.
Promotions, bundles and loyalty offers
Discounts, bundles, loyalty points and competitions linked to injectable treatments are a common source of problems. A price or special for a treatment that uses a prescription medicine can promote the medicine itself, and time-limited offers can encourage people to have a procedure for the wrong reasons. The general advertising guidelines also prohibit offering gifts, discounts or inducements without stating the terms and conditions. In practice, the safest approach is to keep advertised pricing to the consultation, and discuss the cost of treatment during that consultation.
Check the places people forget
Indirect references often hide outside the visible copy: hashtags, emojis, image file names, alt text, booking menu labels, saved Stories and highlights, and posts from years ago. Content from influencers, ambassadors and staff that you arranged or benefited from is treated as your advertising too, so it needs the same review.
Common mistakes we see
- Swapping one generic term for another. Replacing “wrinkle reducing injections” with “anti-wrinkle treatment” or a nickname does not solve the problem if a reasonable consumer still understands the reference.
- Fixing the page copy but leaving the term in URLs, page titles, image file names, alt text or menu labels.
- Leaving old social posts, highlights and pinned posts untouched after updating the website.
- Keeping a public price list for injectables, sometimes buried in a downloadable PDF.
- Assuming that because a practitioner is registered and qualified, the advertising rules apply differently.
- Letting influencers or ambassadors post freely without a written brief.
- Using before and after images that imply results from a prescription injectable.
A practical checklist
- Search your website, including page titles, URLs, meta descriptions and alt text, for product names, ingredient names, nicknames and generic injectable class terms.
- Restructure injectable service pages around the consultation, the practitioner and the concerns discussed.
- Remove public price lists, package prices and per-unit pricing for prescription injectables.
- Remove testimonials and before and after images that promote prescription injectables.
- Audit your Google Business Profile services, products, posts and photo captions.
- Review social captions, hashtags, highlights, bios and pinned posts, including older content.
- Rewrite paid search keywords, ad copy and landing pages.
- Check email and SMS templates for injectable promotions.
- Collect and review all printed and in-clinic material.
- Give influencers, staff and agencies a written brief on what they must not say or show.
- Set a review date to recheck content against the TGA’s latest guidance.
How this fits with other rules
The TGA regulates advertising of therapeutic goods under the Therapeutic Goods Act 1989. It does not regulate the promotion of health services as such, but when advertising for a service also advertises a therapeutic good, the TGA’s rules apply.
Ahpra and the National Boards regulate advertising by registered health practitioners under the National Law, including the ban on testimonials. Their guidelines for advertising higher risk non-surgical cosmetic procedures, effective 2 September 2025, add specific requirements for anyone advertising procedures such as cosmetic injectables, including rules on images and on content directed at under-18s.
The Australian Consumer Law, administered by the ACCC, applies to all advertising and prohibits misleading or deceptive conduct. A single piece of cosmetic marketing can be assessed against all three frameworks, so meeting one does not mean you meet the others.
Frequently asked questions
Did the law change on 7 March 2024?
No. The TGA said the legislation had not changed. What changed was its guidance: it stopped permitting generic terms that it had previously tolerated, so that its interpretation is consistent across industries.
Can we still say we offer cosmetic injectables?
The TGA’s current guidance treats references that present your service as a way to obtain prescription cosmetic injectables as risky. Its suggested approach is to promote the consultation and the concerns or conditions you can discuss, without referring directly or indirectly to the goods. How a particular phrase reads depends on context, so review wording carefully.
Are before and after photos banned?
The TGA said using before and after photos to advertise the use or supply of prescription cosmetic injectables has never been compliant. Its later guidance says the problem arises where it is expressly or implicitly suggested that the after photo is due to a prescription medicine. Ahpra’s cosmetic advertising guidelines also set their own rules on images.
What about our price list?
The TGA named price lists as a form of advertising prescription cosmetic injectables that has never been compliant. Remove public price information for these treatments. Consultation fees can be discussed without reference to the goods.
Does this apply to products that are not prescription medicines?
The current guidance says the restriction does not apply to cosmetic injectables that do not contain prescription-only substances. Advertising for those products must still comply with the Advertising Code and the rest of the Act.
Will the TGA take enforcement action?
In March 2024 the TGA said it would seek voluntary compliance first through education and engagement, and that any later action would be evidence-based and proportionate. It has since announced infringement notices against individuals for alleged unlawful advertising of prescription-only cosmetic injectables on social media. Those are allegations, and each case turns on its facts.
Related articles
- Cosmetic surgery review and Health Ministers’ crackdown explained
- Cosmetic surgery advertising and practice guidelines from 1 July 2023
- ‘Surgeon’ becomes a protected title: what practices must change
- Non-surgical cosmetic procedure guidelines take effect
Need a hand?
If your injectable service pages, social content or price lists were written before 2024, they are worth a careful review. Our TGA advertising compliance service reviews websites, profiles and campaigns against the current guidance, and our work with cosmetic clinics focuses on promoting consultations and practitioners rather than products. We can also help rewrite content through our compliant content 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.