Understanding the TGA’s new guidance on advertising certain aesthetic services
The Therapeutic Goods Administration (TGA) has recently reinforced its position on how certain aesthetic scheduled medications must be presented in advertising. Here’s a clear rundown of what’s changed—and what hasn’t.
What has changed—and what hasn’t
- No change to the law—but a shift in enforcement. The underlying legislation hasn’t changed: substances requiring a prescription still cannot be advertised publicly. What has changed is how the TGA interprets and enforces these rules, closing loopholes that previously allowed indirect or coded references to prescription substances.
- Indirect references are no longer permitted. Even non-specific, generic phrases that imply the availability of prescription-only substances, or related abbreviations and hashtags—are now likely to be regarded as illegal promotional content.
- Testimonials, before-and-after imagery, pricing, and influencer content that promotes prescription-only substances are also restricted. The updated guidance reiterates that using client testimonials, edited images, price listings, and influencer content can risk breach of the advertising rules.
Why this matters
- Consumer protection and safety. These substances carry risks requiring professional medical consultation. Public advertising that implicitly promotes them can mislead consumers and undermine informed consent.
- Widespread non-compliance. An industry audit of 100 cosmetic service websites revealed that 98% used prohibited terms.
Key takeaways for advertising
- Focussing on the service, not the substances. Advertise the benefits of professional consultations and services, such as personalised care or aesthetic advice and consultations—without referencing specific substances or implying access to prescription-only treatments.
- Avoid regulated visual or testimonial content. Steer clear of before-and-after with descriptions that indicate prescription-only substances were used, promotional pricing, or influencer content that could be interpreted as promoting the prescription-only aspect of the service.
Read the Full TGA Guidance
For complete, authoritative details, visit the TGA’s page on “Advertising health services”, particularly the section addressing cosmetic services.