The Therapeutic Goods Administration (TGA) has introduced new rules on how clinics and aesthetic practitioners can talk about treatments like anti-wrinkle injections and dermal fillers. This week, the TGA reinforced their position on this change of legislation and effective immediately, clinics and providers are required to change all advertising, social media, menus, websites and even their clinic name if necessary, to adhere to the new rules.
What does this mean for us as patients? You’ll start noticing changes in how your clinic and aesthetic provider advertise their services including changes to their website, menu of services, booking systems and anything outside of the consultation where treatment is discussed..
The TGA has stated this update was to make sure that all promotional material is clear, safe, and focuses on the professional consultation aspect of the service.
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.
In light of the TGA’s updated regulations on advertising aesthetic treatments, Dr. John Flynn, a seasoned cosmetic medicine practitioner from the Cosmetic Skin Clinic located in Southport on the Gold Coast, offers his perspective on the challenges and potential consequences for patient information and clinic operations. Dr. Flynn emphasised the tightened language around advertising, noting, “in terms like anti-wrinkle injections or cosmetic injectables, which previously were an allowable form of advertising, no longer are.” He expressed concern that the new advertising restrictions might lead to patients being “less informed than they previously were,” as the allowed terminology does not provide clear insights into the treatments available before a consultation.
This, according to Dr. Flynn, could result in patients potentially wasting time and resources on consultations for services that a clinic may not offer. Despite understanding the TGA’s intention to protect patients, Dr. Flynn reflects on whether the regulations will achieve this goal, suggesting that “the patient’s are going to be less informed than they were before”.
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 use of testimonials, claims about the goods, before and after photos, or price lists.
To further illuminate the complexities of navigating aesthetic medicine regulations and industry trends, Dr. John Flynn shared insights on the global exchange of information and the evolving desires of patients and practitioners alike. Amidst the TGA’s stringent advertising guidelines, Dr. Flynn points out a significant modern paradox: while Australian health professionals are tightly bound by regulation, “If you’re a journalist or if you’re a reporter, you can say almost anything that you like.” This discrepancy raises concerns about patients potentially sourcing information from less regulated and possibly less reliable international platforms, which could muddle their understanding and expectations of aesthetic treatments available domestically.
Aimée Rodrigues, features writer for Aesthetic Medical Practitioner highlighted the crackdown from the TGA on unlawful advertising in the wellness and beauty industries:
“One of the TGA’s Compliance Priorities for 2023-24 is to detect and disrupt unlawful advertising of unapproved and high-risk medicines and medical devices used in the wellness and beauty industries including those intended to alter the body’s performance and appearance.”
According to the TGA, the change is focused on ensuring that we, as patients, make informed decisions in a safe environment, and that all discussions and decisions are made within a consultation.
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’.”
