TGA Advertising Compliance

Not in advertising to the public. Anti-wrinkle injections are prescription-only medicines, and prescription-only medicines cannot be advertised to the public. The TGA also treats indirect references as advertising the medicine, so nicknames, abbreviations, descriptions, hashtags, emojis or imagery that point to the product carry the same risk as using its name.

What your practice can promote is the consultation, your practitioners and the practice itself. A page can explain who the patient will see, what the consultation involves and that any treatment options are discussed once the practitioner has assessed them. That keeps the focus on care and advice rather than on a medicine. When we review your site, we restructure pages that are built around a prescription medicine along these lines. We also check them against AHPRA’s guidelines, including the 2025 guidelines for higher-risk non-surgical cosmetic procedures, which apply alongside the TGA rules. Our cosmetic clinics page covers the wider picture.

Prices and specials for treatments that involve a prescription medicine are treated by the TGA as advertising that medicine. That covers price lists on your website, pricing in booking menus, package deals, loyalty offers and social posts promoting a discount or a limited-time special for those treatments.

Booking platforms are easy to overlook, because service names and prices are usually set up once and rarely revisited. As part of the review we check your menus, price pages and promotions, and suggest how to present them around the consultation instead. That might mean listing a consultation with a practitioner, explaining what happens during it and making clear that costs for any treatment are discussed in the consultation once the practitioner has assessed the patient. If you have a particular pricing or promotion question that the published guidance does not settle, we suggest checking it with a health lawyer before it goes live.

Many weight-loss medicines are prescription-only, and prescription-only medicines cannot be advertised to the public. The rules apply to anyone who advertises, including weight-management clinics and telehealth services, and they cover websites, landing pages, ads, emails and social posts. The TGA treats indirect references, such as nicknames, descriptions, hashtags, emojis, imagery or pricing that point to a particular medicine, as advertising that medicine, and weight-loss medicines have been one of its areas of focus.

Your practice can promote the weight-management service itself: the consultation, the practitioners and other health professionals involved, how assessment and follow-up work, and the support patients receive along the way. Any decision about medicine is made by the practitioner with the patient, not in your marketing. We review your pages, ads and enquiry funnels with this in mind and rewrite them around the service. Our weight management page covers the wider marketing picture for these clinics.

The Therapeutic Goods Advertising Code has rules on testimonials and endorsements in advertising for therapeutic goods, including endorsements by health professionals. If your practice is run by registered practitioners, the National Law ban on testimonials applies on top of that. So reviews about products or treatments need care wherever your practice uses them in its own marketing.

We look at how reviews appear on your website, in review widgets, on product pages, in social posts and Stories you have reshared, and in content from influencers or ambassadors. We also check where a practitioner is shown recommending a product the clinic sells, as that can raise the rules on endorsements. For each item we explain why it is a risk and suggest what to do, whether that is removing it, rewording the surrounding copy or changing how reviews are displayed. Where it is unclear how the rules apply to a particular product or review, we suggest asking a health lawyer or the product sponsor.

Often, yes. Where a product can lawfully be advertised to the public, such as a primary sunscreen, many supplements or a support or home-use device, the advertising must include the mandatory statements or health warnings that apply. A common example is a direction to read the label and follow the directions for use. A social post promoting a product your clinic sells is advertising, so the same expectations apply there as on your website.

Which statements are needed depends on the product and how it is being advertised, and short formats such as Stories or reels make them easy to leave out. As part of the review we check posts, captions and product listings for missing statements, make sure claims match what the product is approved or listed for on the ARTG, and give you wording to add. If a product’s requirements are unclear, the sponsor or supplier is usually the right place to confirm them, along with the TGA’s published guidance.

No. The two look at different rules, and most practices need both. This service focuses on the TGA rules for advertising therapeutic goods, which apply to anyone who advertises. Our AHPRA work looks at the guidelines for registered practitioners, including the 2025 guidelines for higher-risk non-surgical cosmetic procedures, which apply alongside the TGA rules rather than instead of them.

In practice they overlap. A treatment page might raise a TGA issue by naming a prescription medicine and an AHPRA issue by including a testimonial or an unsupported claim. If your practice offers cosmetic injectables or weight management, or sells products with therapeutic claims, it makes sense to look at both. We can run this review together with our AHPRA compliance audit so your team receives one set of findings, ranked by risk, with wording that addresses both sets of rules. If you have already had an AHPRA audit, this review fills in the therapeutic goods side.

The TGA rules apply to anyone who advertises therapeutic goods, not only manufacturers. An influencer or ambassador posting about your treatments or products is advertising, and the rules still apply to your practice when that content promotes you. Responsibility does not move to the influencer, or to an agency, just because they wrote or published the post.

That makes influencer content worth reviewing as carefully as your own. We look at current and past posts, captions, hashtags and Stories highlights from the people who promote you, and at any brief or guidance you give them. Typical issues include indirect references to prescription medicines, claims that go beyond a product’s ARTG entry, missing mandatory statements, and testimonials or endorsements. For each issue we explain the risk and suggest what to change, and we can help you write a clearer brief for future collaborations. Your practice can then approve content before it goes up, rather than finding problems afterwards.

It depends on what the product is and what is being said about it. Ordinary cosmetics are generally not therapeutic goods, so many skincare products are not on the ARTG at all. Therapeutic claims can change that, so a cosmetic described as treating a skin condition may be treated as a therapeutic good. Primary sunscreens are regulated as medicines, many supplements are complementary medicines, and supports, braces and some home-use devices are medical devices.

When we find a product making therapeutic claims, we check what its ARTG entry, if it has one, says it is approved or listed for, and whether your marketing goes beyond that. If a product does not appear to have an entry, we flag it rather than reach a conclusion ourselves, and we suggest you ask the sponsor or supplier, or a health lawyer, before continuing to promote it. In the meantime we can give you wording that removes the therapeutic claims from your own marketing.

No. The Medical Marketers is a marketing agency, not a law firm. We know the TGA advertising rules and the AHPRA guidelines well and apply them to your actual marketing, but our review identifies risks and suggests compliant alternatives rather than giving a legal opinion about your obligations. Responsibility for your advertising stays with your practice.

Some questions go beyond what a marketing review should answer. If you are unsure whether a product is a therapeutic good, how a product’s ARTG entry applies to a particular claim, or how the rules apply to an unusual campaign, the right sources are a health lawyer, the product sponsor or supplier, or the TGA’s published guidance. The same applies if you have received a complaint, warning or direction from the TGA. We are happy to share our findings with your adviser, and to apply any advice you receive to your pages, posts and product listings, so the changes are made consistently across your marketing.

It depends on the scope. A practice with a small website, a single social account and no products for sale has less to review than a group with several locations, active ad campaigns, influencer partnerships and a retail range. The number of older posts that are still publicly visible also makes a difference, because indirect references to medicines can build up there over time.

Before we start, we agree what is covered and ask for viewing access to your ad accounts, social pages, booking platforms and any email or influencer content you want included. We also ask for a list of the products you sell or recommend so we can check their ARTG entries. Once we have that, we confirm the timing with you. If we find a serious issue partway through, such as a live ad naming a prescription medicine, we do not wait for the final report. We flag it straight away so you can decide whether to pause or change it.

We walk you through the findings on a call and help you decide what to tackle first. Many practices start with the serious items, such as references to prescription medicines in live ads or booking menus, then work through the rest in an order that suits their time and resources.

You can make the changes yourself using our replacement wording, or we can make them for you where we have access, including restructuring treatment pages around consultations and adding mandatory statements to product listings. You approve the new wording before it goes live. Once changes are made, we can recheck them to confirm each issue has been dealt with. From there, some practices choose ongoing pre-publication review of new ads and posts, new content written with the rules in mind through our compliant content service, or compliance training so their own team can spot issues early.

Yes. Pre-publication review is an optional ongoing service for practices that want new content checked before it is published. You send us draft ads, social posts, captions, emails, product listings or influencer content, and we check them against the TGA advertising rules and, where relevant, the AHPRA guidelines.

Each draft comes back either with no changes suggested or with compliant replacement wording, along with a short explanation of why. We look for the same issues as in a full review: indirect references to prescription medicines, prices or specials for medicine-based treatments, claims beyond a product’s ARTG entry, missing mandatory statements, and testimonials or endorsements. Checking content before it goes live is usually simpler than fixing it later, particularly on social media, where posts are shared and saved. The decision to publish stays with your practice, since responsibility for advertising does not move to us, and complex product questions still go to a health lawyer or the product sponsor.