Can you advertise Botox in Australia?

Why you can’t name it

Under the Therapeutic Goods Act, prescription-only medicines can’t be advertised to the public. Most injectables contain a Schedule 4 substance, so the product itself is off-limits in your public marketing. However carefully you word it, the product can’t be promoted to the public.

It extends past the brand name. You can’t reference the substance directly or indirectly, which catches nicknames, abbreviations and hashtags. “#botox”, “tox” and “baby botox” are all caught. So is a business name that leans on injectable language, which is assessed case by case on what a consumer would take from it.

The change that broke the old advice

For years the accepted workaround was to swap “Botox” for “anti-wrinkle injections” or “dermal fillers”. That advice is now wrong. Since the TGA’s tightening on 7 March 2024, those generic terms are no longer expressly permitted where a reasonable consumer reads them as promoting a prescription medicine. If your website, price menu or socials still use them, your “compliant” wording is the breach.

The legislation didn’t change in March 2024. The TGA’s enforcement interpretation did. There’s nothing to wait out.

What you can say instead

Advertise the consultation and the concern, not the treatment or the product. The TGA’s own worked example is “call our clinic for a consultation to discuss treatment options for migraine.” For a cosmetic clinic, that means describing the concern, like frown lines or facial ageing, and inviting a consultation, rather than pricing a named injectable.

Treatments with no prescription-only ingredient, such as energy-based devices like laser, ultrasound and radiofrequency, may not be caught by the TGA’s ban, subject to ARTG inclusion and the Advertising Code. That doesn’t put them outside the rules. Ahpra’s advertising rules still apply, and its higher-risk guideline lists thread lifts and procedures using platelet-rich plasma. Check each treatment with your adviser before you promote it.

The traps that catch clinics

• ▸Prices. Don’t publish a price for a prescription-only injectable, per unit or total. Stating the price is likely to be treated as advertising the product.
• ▸The booking widget. An online booking system that lets a client self-select a prescription-only injectable, or shows its price, is itself likely an advertisement for it.
• ▸History. Old posts and hashtags must be cleaned up retroactively, and you’re responsible for comments and tags on pages you control.
• ▸“Education only” labels. A disclaimer doesn’t cure a promotional post. If it promotes use, it still can’t name the prescription goods, even generically.