Australia’s Therapeutic Goods Administration (TGA) has recently updated its guidance regarding the advertising of cosmetic injectables. The move comes as the TGA identified discrepancies in the promotion of prescription medicines across different sectors, prompting a need for clarity and uniformity in regulatory interpretation.

Traditionally, the TGA permitted indirect references to prescription medicines in advertisements for cosmetic health services, albeit under specific conditions. Clinics offering services such as ‘wrinkle reducing injections’ could advertise their offerings using generic, non-product specific terms.

However, explicit references to specific products or ingredients were prohibited. This approach aimed to allow clinics to differentiate themselves while ensuring compliance with regulatory frameworks.

Recent observations by the TGA revealed that health services in other industry sectors were also advertising prescription medicines, albeit indirectly. Terms like ‘weight loss injections,’ ‘medicinal cannabis,’ or ‘nicotine vaping products’ were being used to promote services, implying the availability of prescription medicines. The TGA interpreted this as unlawful promotion of therapeutic goods through health service advertisements.

In a claim to address the suggested inconsistency, the TGA has revised its guidance, disallowing references to terms like ‘wrinkle reducing injections’ if they imply the promotion of prescription medicines. The updated guidance emphasises that advertising the use or supply of prescription medicines, including most cosmetic injectable products, has never been compliant with therapeutic goods regulations.

What you need to know

• Injectors must NOT use the terms “dermal filler”, “injections”, “injectables”, “anti-wrinkle injections” in any marketing material or signage – including business/company names.
• Removal of before & after images with use of pharmaceutical products – any existing images must be archived or deleted, including on any physical promotional material (i.e brochures, signage displays, etc).
• Price lists must be removed from website and other marketing material such as paper/digital clinic brochures (in which refer to cosmetic injectable services)
• Social media hashtags must not include the terms listed above
• Promotion of services must only elucidate to consultations offered, and not specific services

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