If your practice offers cosmetic injectables or non-surgical treatments, the Therapeutic Goods Administration has some of the most far-reaching advertising rules in the healthcare sector. Many practitioners are still unknowingly breaching them every day, and the consequences are getting harder to ignore. At ContentClicks, our plastic surgery marketing specialists help practices build advertising strategies that are both compelling and fully compliant. This guide breaks down exactly what the TGA requires and what it means for your marketing.
The TGA regulates the advertising of therapeutic goods in Australia under the Therapeutic Goods Act 1989. Cosmetic injectables, including botulinum toxin products and most dermal fillers, are classified as Schedule 4 prescription-only medicines under the Poisons Standard. That classification is the source of the entire framework.
Because these products are prescription-only, they cannot legally be advertised to the general public. This rule has been in place for decades. What changed in March 2024 was the TGA’s enforcement position. The regulator updated its guidance to close a longstanding loophole that had allowed clinics to use generic terms such as “wrinkle reducing injections” or “anti-wrinkle injections” in their advertising. The TGA now treats even those indirect references as unlawful advertising of prescription medicines. You can read the full TGA guidance on cosmetic injectable advertising on their website.
This is where most clinics run into trouble, because the list of prohibited content is broader than many people realise.
Naming any prescription-only injectable product in public advertising is prohibited. This includes brand names, generic names and active ingredients. Terms like “Botox”, “Juvederm”, “botulinum toxin”, “hyaluronic acid” and “dermal filler” all fall into this category when used in the context of promoting your services.
Since March 2024, previously common terms like “anti-wrinkle injections”, “wrinkle reducing injections” and “lip filler” are also off limits where a reasonable consumer would understand them as promoting the use of a prescription medicine. The TGA’s position is that these terms draw the audience’s mind to a specific class of prescription goods, which makes them indirect advertising.
Where a before and after photo makes it apparent that the result was achieved through a prescription-only injectable, that image constitutes advertising for a therapeutic good and cannot be used publicly. This applies across your website, social media and any other advertising channel.
Publishing pricing for injectable treatments is considered advertising of a prescription-only good and is prohibited. This includes cost-per-unit pricing and bundled treatment pricing.
The TGA explicitly states that the ban extends to acronyms, nicknames, abbreviations and hashtags that a consumer could reasonably interpret as a reference to a prescription-only injectable. This means social media shorthand that alludes to specific treatments is also non-compliant.
The rules do not shut down your marketing entirely. The TGA’s guidance is clear that clinics can advertise the nature of consultations and the types of services available, provided those descriptions do not reference prescription-only medicines.
In practice, this means you can describe your clinic as a provider of cosmetic consultations, facial treatments, skin rejuvenation services or aesthetic medicine, without naming or alluding to specific injectable products. You can promote your practitioners’ qualifications, your consultation process, your approach to patient care and the experience of attending your clinic.
Educational content sits in a different category. Information shared between a practitioner and a patient in a private consultation is not subject to the advertising rules. Public educational content, however, must not have the effect of promoting the use or supply of a prescription-only medicine, even if framed as informational. Adding a disclaimer that content is “for educational purposes only” does not make it compliant if it would otherwise meet the definition of advertising.
The Australian Society of Aesthetic Plastic Surgeons has advised that the overarching approach should be to promote the consultation itself and the expertise of the practice, rather than the specific treatments involving prescription medicines.
The scale of non-compliance across social media in Australia is significant. In the 2024 to 2025 financial year, the TGA requested the removal of over 13,700 unlawful advertisements from digital platforms, many of them related to cosmetic injectables.
The TGA now actively monitors online content, including Instagram, Facebook, TikTok and website content. It also collaborates with digital platforms to identify and act on alleged breaches. Influencers and ambassadors who post about injectable treatments on behalf of a clinic are considered advertisers under the Act, and the clinic remains responsible for their content.
Historical posts are not exempt. The TGA expects clinics to review all existing advertising and bring it into compliance, including content published before the March 2024 guidance update.
Non-compliance with TGA advertising rules is not a minor administrative matter. The Act provides for civil penalties of up to $1.65 million per breach for individuals and $16.5 million per breach for corporate entities. Criminal penalties can include fines and imprisonment for serious contraventions.
In practice, the TGA typically begins enforcement with warning letters and directions to remove non-compliant content within strict timelines. Infringement notices can be issued without court proceedings. For repeated or serious breaches, the TGA has signalled its willingness to pursue formal legal action.
Beyond financial penalties, a formal investigation can result in platform takedowns, reputational damage and disruption to your campaigns at the worst possible time.
Work through this before publishing any content related to injectable or cosmetic treatments.
Are cosmetic injectables banned from advertising in Australia?
Yes, under the Therapeutic Goods Act 1989. Most cosmetic injectables contain Schedule 4 prescription-only substances and cannot be advertised to the general public. This applies to direct and indirect references, including generic terms, brand names, active ingredients and visual content that implies injectable results.
Can I use the term “anti-wrinkle injections” on my website?
No, not since the TGA’s March 2024 guidance update. Generic terms like “anti-wrinkle injections”, “wrinkle reducing injections” and “dermal fillers” are now prohibited where a reasonable consumer would understand them as promoting a prescription-only injectable service.
Can I post before and after photos of injectable treatments on Instagram?
Generally, no. If the result depicted in a before and after photo is attributable to a prescription-only injectable, publishing that image publicly is likely to constitute unlawful advertising of a therapeutic good. This applies to all public-facing platforms including Instagram, Facebook and your website.
What can I legally advertise as a cosmetic clinic?
You can advertise your consultation services, your practitioners’ qualifications, your clinic’s approach to care and the general nature of your aesthetic medicine practice. Your advertising should focus on the service experience rather than specific treatments involving prescription-only medicines.
Do TGA rules apply to old social media posts?
Yes. The TGA expects all existing advertising, including historical social media content, to comply with current requirements. Old posts that reference prescription-only injectables should be removed or updated.
What are the penalties for breaching TGA advertising rules?
Civil penalties can reach $1.65 million per breach for individuals and $16.5 million for corporate entities. The TGA also issues infringement notices and can direct the removal of non-compliant content within strict timeframes. Serious or repeated breaches can result in court proceedings.
Does the TGA monitor social media for compliance?
Yes. The TGA actively monitors online content and collaborates with social media platforms to identify and address non-compliant advertising. In the 2024 to 2025 financial year alone, over 13,700 unlawful advertisements were removed from digital platforms at the TGA’s request.
Navigating TGA rules does not mean your practice has to disappear from the internet. It means your marketing needs to shift its focus from specific products to the expertise, care and consultation experience your practice offers. Done well, that approach builds deeper trust with prospective patients than a list of injectable treatments ever could.
Getting there requires a clear strategy, content that is written with compliance built in from the start, and a team that understands both the creative and regulatory sides of healthcare marketing.
If you are ready to market your practice confidently and compliantly, get in touch with our team today and let us build a strategy that works within the rules without compromising on impact.
Australian Health Practitioner Regulation Agency. (2025). Guidelines for advertising higher risk non-surgical cosmetic procedures. AHPRA. https://www.ahpra.gov.au/Resources/Cosmetic-surgery-hub/Cosmetic-procedure-advertising-guidelines.aspx
Australian Society of Aesthetic Plastic Surgeons. (2024). TGA advertising guidance updated. ASAPS. https://aestheticplasticsurgeons.org.au/news/tga-advertising-guidance-updated/
Therapeutic Goods Administration. (2024). Referring to cosmetic injectables in advertising. Australian Government Department of Health and Aged Care. https://www.tga.gov.au/news/media-releases/referring-cosmetic-injectables-advertising
Therapeutic Goods Administration. (2025). TGA releases updated social media advertising guidance. Australian Government Department of Health and Aged Care. https://www.tga.gov.au/news/media-releases/tga-releases-updated-social-media-advertising-guidance-support-improved-compliance
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