The banning of referring to prescription only products as ‘anti-wrinkle injection’ and ‘dermal filler’ by the TGA caught the majority of practitioners by surprise, especially with learning that the changes came into effect on 18th December last year.
From the TGA “to support the consistent application of legislation related to the advertising of therapeutic goods across all industry sectors, on 18 December 2023 previously published guidance which included certain terms considered at the time to be acceptable was removed from our website. These terms included ‘anti-wrinkle injections’ and ‘dermal fillers’. This is because these terms refer to (by drawing the audience’s mind to) prescription only products”.
The Australasian Society of Aesthetic Plastic Surgeons (ASAPS) feels that the implementation of this regulatory change could have been executed with more professionalism from the TGA with more respect to the health practitioners this may affect and the consequences that it may have on their practices.
Dr Lily Vrtik, Specialist Plastic Surgeon and ASAPS Board Member stated “the lack of clear guidance from TGA also present significant challenges, not only for patient information provision, but also for proactive practitioners who have contributed to patient education on media and public platforms to facilitate autonomy and informed choices in the area of cosmetic medicine”.
However, ASAPS does acknowledge that these new regulations can also be viewed by the industry as an opportunity for practitioners and clinics to revisit the way they advertise to and educate their patients, without ignoring or downplaying risks, and with a continued focus on patient safety first and foremost.
Specialist Plastic Surgeon and ASAPS President, Dr Tim Edwards added that “whilst the new guidelines make it even more complex for aesthetic practitioners and clinics to convey messaging about their injectables service in marketing materials, an alternative is to refer to the service of injecting or injectable product with the broader category of treatment, for example ‘Our clinic can provide consultations on reducing the appearance of wrinkles’”.
At present, we too await additional clarification and guidance from the TGA, expected this month.
More information on the TGA revised guidance will be published at Advertising for health services | Therapeutic Goods Administration (TGA) mid-late January.