Legislation: Injectables Industry

Legislation: Injectables Industry

Health professionals need to maintain professional standards and be aware of the implications of their actions, as in all professional circumstances.

The Therapeutic Goods Administration (TGA) has updated its guidance on advertising cosmetic injectables to ensure advertising rules are applied consistently across all industries that deal with therapeutic goods. Health practitioners must be aware that their professional obligations apply to their online activities in exactly the same way as a face-to-face consultation with a patient.

Penalties were recently increased in relation to regulated health service advertising offences. The penalties in the case of an individual was increased from $5,000 to $60,000, and in the case of a body corporate, the penalties were increased from $10,000 to $120,000.

Social Media Compliance for the Injectables Industry (Australia)

Marketing within the injectables and cosmetic treatments industry is subject to strict regulations to protect consumer safety, ensure ethical advertising, and uphold professional standards. Whether you're a clinic, franchise, or practitioner, it’s essential that your social media content complies with the following legislation and industry codes:

1. Therapeutic Goods Advertising Code

Regulator: Therapeutic Goods Administration (TGA)

  • Prohibits direct advertising of prescription-only medications (e.g. Botox, dermal fillers) to the public.
  • You cannot mention brand names of S4 medicines or promote their availability.
  • Avoid any implication that injectables are cosmetic-only or risk-free.
  • Testimonials relating to clinical outcomes (e.g. pain relief, appearance, emotional wellbeing) are not permitted.
  • All content must include appropriate disclaimers and warnings, and not create unrealistic expectations.

 

2. Ahpra Guidelines for Regulated Health Services

Regulator: Australian Health Practitioner Regulation Agency (Ahpra)

  • Applies to all registered health professionals (e.g. nurses, doctors) performing injectables.
  • Prohibits testimonials and reviews that promote the efficacy of a treatment.
  • You must not use before-and-after imagery that could be seen as misleading or that exaggerates outcomes.
  • Claims about outcomes must be evidence-based and not create false hope.
  • Advertising must not create an unreasonable expectation of benefit or trivialise risks.

 

3. State Health and Licensing Requirements

  • Requirements may differ by state regarding who can administer injectables and what qualifications are needed.
  • Ensure all content accurately reflects the qualifications and licensing status of practitioners.
  • It is illegal to imply a practitioner is qualified to perform injectables if they are not appropriately trained and licensed.

 

How Content Monarchy Helps Reduce Risk for Injectables Clinics and Franchises

  • All content is centrally managed and pre-approved to meet TGA and Ahpra standards.
  • No use of brand names or testimonials, ensuring compliance from day one.
  • Local clinics can customise content while staying within strict industry advertising rules.
  • Access to compliant, professional visuals and captions to maintain trust and brand integrity.
  • Monthly updates and education keep teams informed about evolving regulations.