3 Ad Mistakes Clinics Make After the TGA Crackdown
The TGA has cracked down on unlawful advertising of prescription-only cosmetic injectables. A landmark audit of 100 websites found 98% were in breach of advertising laws — largely due to misuse of restricted terms and promotional techniques.
Even now, many clinics are unaware they’re non-compliant — or are unsure how to adapt their messaging without losing effectiveness. Below are three of the most common advertising missteps we see, plus easy ways to fix them.
AHPRA has introduced new guidelines for practitioners who perform and advertise higher-risk non-surgical cosmetic procedures, effective from 2 September 2025. These updates — combined with the ongoing TGA crackdown — have created a new era of TGA-compliant advertising for cosmetic clinics across Australia.
Key updates include:
Mandatory Cooling-Off Period: A seven-day cooling-off period for individuals under 18 considering non-surgical cosmetic procedures.
Advertising Restrictions: Bans on targeted advertising to minors and the use of influencer testimonials in promoting cosmetic procedures.
Enhanced Practitioner Training: Requirements for additional training and experience for practitioners performing these procedures.
Even now, many clinics are unaware they’re non-compliant — or are unsure how to adapt their messaging without losing effectiveness. Below are three of the most common advertising missteps we see, plus easy ways to fix them.
Mistake 1: Using Prohibited Terms Like “Botox,” “Filler,” or “Anti-Wrinkle”
It might feel harmless to mention popular treatment names like Botox or “anti-wrinkle injections,” but under TGA advertising regulations, any direct or indirect reference to prescription-only products is banned. This includes brand names, treatment category names, and even slang or abbreviations.
Common violations include:
“We offer dermal fillers and Botox”
“Our anti-wrinkle packages target forehead lines”
“Book your filler touch-up today!”
Why it matters: These terms promote a Schedule 4 medicine, which cannot be advertised to the public under Australian law. Even if your intention is educational or descriptive, it can still be deemed promotional.
✔️ Solution: Shift your language from product-focused to outcome-focused.
Instead of:
“We offer anti-wrinkle injections”
Say:
“Our clinicians provide consultations to help reduce the appearance of fine lines, supporting a refreshed and natural look.”
This approach supports cosmetic injectables ad compliance in Australia while also focusing on client needs and desired outcomes.
Mistake 2: Using Before-and-After Photos in Public Advertising
Before-and-after images are one of the most tempting tools in aesthetic marketing. But under both AHPRA marketing rules (2025) and existing TGA guidelines, these visuals can:
Create unrealistic expectations
Be interpreted as a guarantee of results
Serve as an indirect advertisement of a prescription product
If used publicly on your website, social media, or paid ads, they are often in violation — especially when tied to a treatment that involves prescription-only substances.
✔️ Solution: Replace them with compliant testimonials, general service descriptions, or educational content.
For example:
“Many of our clients report feeling more confident and refreshed after treatment. Each result is tailored and achieved through a collaborative consultation process.”
Also consider:
General “feel-good” imagery (e.g., smiling clients, calming treatment rooms)
Client feedback that focuses on experience, not outcomes
Clinical team profiles that showcase expertise and qualifications
If you still wish to share before-and-afters, limit them to in-clinic settings during consultations, where they can be presented with proper context.
Mistake 3: Listing Prices for Prescription-Based Treatments
Another common trap is listing fixed pricing for services like cosmetic injectables. While it might feel transparent, advertising pricing for Schedule 4 treatments is classed as promotion and is therefore banned under TGA-compliant advertising guidelines.
You cannot say:
“Lip filler $389”
“Anti-wrinkle injections from $12/unit”
Even bundling these prices with vague descriptions (e.g., “refresh package $450”) can still put you at risk if the treatment involves prescription-only substances.
✔️ Solution: Keep pricing discussions within the consultation process.
Try this instead:
“We offer tailored treatment plans based on your goals. Pricing is discussed during your personalised consultation.”
This keeps you compliant, builds trust, and allows you to recommend treatments based on genuine clinical advice rather than price shopping.
Final Thoughts: Compliance Doesn’t Have to Kill Your Marketing
AHPRA marketing rules in 2025 and the recent TGA crackdown can feel limiting at first glance — but with the right strategy, your marketing can still be ethical, effective, and engaging.
In fact, the shift away from aggressive sales tactics creates space for more human, story-driven communication — the kind that builds long-term trust with your audience.
✔️ Instead of selling a product, sell a feeling
✔️ Instead of promoting an injectable, promote a personalised experience
✔️ Instead of listing prices, invite meaningful consultations
If you're unsure whether your current advertising is compliant — or want help reworking your copy, offers, or visuals — we're here to help.
📩 Reach out for friendly, expert advice tailored to your clinic and audience.
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To better protect patient safety and reduce misleading promotions — especially for vulnerable groups like minors — the Australian Health Practitioner Regulation Agency (AHPRA) and the Therapeutic Goods Administration (TGA) have updated the rules for advertising non-surgical cosmetic procedures.
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From 2 September 2025.
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Any practitioner performing higher-risk non-surgical cosmetic procedures, such as:
Anti-wrinkle treatments
Cosmetic injectables
Dermal filler services
These updates apply to both medical and non-medical clinics advertising or performing such treatments.
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Clinics must now implement a seven-day cooling-off period for clients under 18 years old before performing any non-surgical cosmetic procedure.
This rule is designed to:Prevent impulsive decisions
Give minors time to fully consider the treatment
Support ethical, informed consent
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No.
Influencers and brand ambassadors can no longer promote cosmetic treatments if they’ve:Been offered payment, discounts, or free treatments
Shared personal experiences that imply therapeutic outcomes
Even unpaid testimonials that mention specific results may be in breach of these new rules.
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Practitioners must meet enhanced training and experience standards to perform high-risk cosmetic procedures. This includes:
Verified qualifications
Relevant clinical experience
Continuous education in cosmetic medicine
This change is meant to ensure better outcomes and patient safety across the industry.Practitioners must meet enhanced training and experience standards to perform high-risk cosmetic procedures. This includes:
Verified qualifications
Relevant clinical experience
Continuous education in cosmetic medicine
This change is meant to ensure better outcomes and patient safety across the industry.
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In 2024, the TGA conducted a major audit of 100 cosmetic clinic websites. Shockingly, 98% were found non-compliant, mainly because they:
Used prohibited terms like Botox, filler, or anti-wrinkle injections
Showed before-and-after photos
Listed pricing for prescription-only treatments
This prompted a renewed push to enforce existing advertising laws more aggressively.
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Avoid using brand names or treatment types that refer to prescription-only medications (e.g., “Botox” or “filler”)
Don’t list prices for prescription-based services
Remove before-and-after photos from public advertising
Focus on services and experience, not products
Use compliant testimonials that do not reference therapeutic outcomes
