After being blind-sided by the banning of referring to prescription only products as ‘anti-wrinkle injection’ and ‘dermal filler’ by the TGA in December 2023, the updated guidance on advertising health services has finally been released.
From the TGA “To resolve any inconsistency in interpretation across industry areas, the TGA no longer permits references to terms such as ‘wrinkle reducing injections’ where those terms would result in a reasonable consumer understanding the intention of the content is to promote the use or supply of a prescription medicine.
The revised guidance on advertising cosmetic injectables is now available on the TGA website at Advertising health services. This material reinforces that the legislation itself regarding cosmetic injectables has not changed, and advertising the use or supply of prescription medicines, including most cosmetic injectable products (as opposed to services), has never been compliant with the therapeutic goods framework. This includes through use of testimonials, claims about the goods, before and after photos, or price lists.
The update aligns with the focus of other regulators on health professionals performing non-surgical cosmetic procedures and acknowledges the increasing vulnerability of Australians influenced by advertising in the cosmetic space. Prescription only medications carry higher risks than goods available for self-selection. Decisions about treatments that involve the use of prescription medicines should only be made by a health professional in consultation with each individual patient.”
Of particular interest to the Australasian Society of Aesthetic Plastic Surgeons (ASAPS) and our members is the definition of what is advertising, updated guidance of treatments involving prescription-only medicines, referring to prescription-only medicines in company, business or trading names, and cosmetic injection services.
With different guidance for cosmetic injectables that do or don’t contain any prescription-only medicine the implementation of this guidance will take a renewed focus on messaging and marketing to ensure compliance.
Dr Lily Vrtik, Specialist Plastic Surgeon and ASAPS Board Member stated, “With the TGA expecting the industry to take prompt steps to review existing advertising of cosmetic injectables to bring clinics and practices into line with the new guidance, its imperative practitioners review current offerings, advertising, marketing, social media channels, even price lists, and make adjustments accordingly and quickly.”
ASAPS acknowledges that this updated advertising guidance is an opportunity for practitioners and clinics to revisit the way they advertise to and educate patients, with a continued focus on ethical practice and patient safety first and foremost. Specialist Plastic Surgeon and ASAPS President, Dr Tim Edwards stated, “The overarching plan for practitioners should be that advertising refers only to the nature of the consultation the service provides. As an example, ‘our clinic provides consultation about reducing wrinkles’.”
More information on the TGA Advertising Health Services can be found here and the latest press release here.
