The Complete Guide to Advertising Cosmetic Injectables in Australia

Key Takeaways

• Strict Advertising Rules Apply: The TGA and AHPRA closely regulate how cosmetic injectables are promoted in Australia to ensure client safety and ethical marketing.
• Accuracy and Transparency Are Essential: Advertising must provide balanced information about both benefits and risks. Misleading or minimising language, such as “quick,” “painless,” or “simple”, is not permitted.
• Testimonials and Manipulated Images Are Prohibited: Using testimonials or retouched “before and after” photos is banned. All imagery must be accurate, professional, and free from emotional or lifestyle elements.
• Practitioners Are Accountable: Registered practitioners are responsible for ensuring compliance across all marketing, including social media and influencer content. Qualifications and titles must be presented truthfully.
• Ethical Messaging Is Required: Advertising must not imply that cosmetic treatments increase self-esteem, restore youth, or “fix” normal ageing or appearance. Outcomes should never be guaranteed.
• Compliance is a Legal Obligation: Breaches can lead to education, disciplinary action, or prosecution. Businesses must review and update all promotional materials promptly to ensure compliance with current TGA and AHPRA standards.

If you have anything to do with the cosmetic injectables industry in Australia, you would by now have heard of the changes that were recently implemented. These changes were designed to keep clients safe and businesses reputable. As part of running, owning or working in a business that deals with aesthetics, knowing about these changes is crucial and not being informed is no excuse should you be caught out. 

One area that cosmetic injectors should be aware of pertains to advertising cosmetic injectables. Because cosmetic treatments are not driven by a health care need and are not “necessary”, it is imperative that potential clients are targeted ethically. 

The TGA’s Role

The TGA, or Therapeutic Goods Administration, governs how cosmetic injectables are advertised in Australia. They have strict guidelines that all practitioners must abide by, or face severe consequences. Claims about cosmetic injectable outcomes must be clear, concise, and backed by evidence, avoiding all ambiguity. Deceptive tactics are not permitted, such as using language to minimise treatments (for example, fast, quick, easy, simple, painless). 

Advertising must remain honest with regard to outcomes and risks, and not downplay the potential negative results. Recovery times must be highlighted and not dismissed, as should the amount of pain experienced and the necessary aftercare. The information provided in advertisements must highlight both sides (advantages and risks) and be accurate: risks and side effects must be mentioned, and expressions that guarantee a result are banned (“wrinkle-free”). 

Additionally, businesses must note that outcomes are as individual as the client and cannot be guaranteed. Normal appearances, such as the ageing process or natural differences in a body or face, must not be touted as something to be “fixed”, and this extends to practitioners being aware of potential clients who may have psychological or mental concerns relating to perceived appearances. A cosmetic treatment must not be advertised as a solution to “increase self-esteem” or “restore youthfulness”, or that someone will be less attractive if they don’t have a procedure. Guidelines clearly state that financial gain from procedures must be put second to client safety.

Social Media and Advertising

The growing use of social media and influencers requires registered practitioners to take responsibility for all content used to advertise their cosmetic injectables business, ensuring it meets advertising guidelines. Influencer comments or shared content related to a procedure may be classified as advertising.

Key Advertising Rules:

• Advertising must not contain links to social media or digital accounts.
• Cosmetic injectable procedures must not be advertised as competition prizes, as this minimises their seriousness and risks.

Practitioner Responsibilities

Practitioners working in a cosmetic injectables business are responsible for ensuring that advertising adheres to the guidelines and must report instances where it doesn’t. Advertising must be honest with regard to the training and title of practitioners. It is illegal to advertise a worker as something they are not, and qualifications must be clearly detailed and not be misleading. The expectations that advertising creates must be realistic; terms such as “expert”, etc, should not be used. 

Photos, Testimonials and Advertising

Testimonials are banned as they can create unrealistic expectations. Furthermore, photos used in advertising must adhere to strict regulations:

• Images must be “true” depictions (not airbrushed or photoshopped).
• If a “before and after” comparison is used, both photos must be as similar as possible (e.g., lighting, pose).
• The “after” photo must not be more prominent in the advertisement.
• The “after” photo must accurately detail the time elapsed since the treatment.

Photos must not be of clients under the age of 18, sexualise clients or procedures, and be professional in their display – no dancing, singing or presentations/commentary that is not designed to be informative or educational. Photos depicting emotional reactions (such as crying with happiness after a procedure), “lifestyle” shots (e.g., on holiday), or the use of emojis are also banned. Advertising must not display a client’s name or suggest that cosmetic injectables are the only solution if one is dissatisfied with their appearance. 

The TGA has stated that, while there is no specific timeframe for businesses to comply with the changes in advertising, it expects “prompt steps” to be taken. Compliance actions range from education and guidance to criminal prosecution.