Why we can no longer state treatments available in our clinic

In light of recent changes, patients and customers have contacted us about the changes that all Australian practitioners must adhere to. Patients are confused about the sudden secrecy and changes in the way that we can display our treatments, the services we offer and prices for treatment.

While it is not our intention to be vague about what services we offer, we are limited by laws in publicly displaying and advertising a majority of our services.

The Therapeutic Goods Administration (TGA) has updated its guidance on advertising cosmetic injectables to ensure advertising rules are applied consistently across all industries that deal with therapeutic goods.

"Historically, the TGA has allowed indirect references to prescription medicines to be referenced in advertisements related to cosmetic health services. This was allowed only in the context of promoting the service and only by using generic non-product specific terms such as ‘wrinkle reducing injections.’ Express references to products or ingredients themselves, such as ‘Botox’ or ‘botulinum toxin’, were not permitted. The TGA considered this a pragmatic approach which would allow cosmetic clinics who offered these services to differentiate themselves from those that did not.

Recently, the TGA has observed that clinics and health services in other industry areas are advertising the availability of prescription medicines, usually by referring to a class of goods (for example ‘weight loss injections’, ‘medicinal cannabis’ or ‘nicotine vaping products’). The TGA has interpreted that promoting a health service in this way is also an advertisement for a therapeutic good that refers to prescription medicines, which is unlawful. 

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 TGA has implemented stricter regulations to ensure that advertising for cosmetic injectables is not able to be found by consumers.

The main changes that clients will see:

✦ No client testimonials or reviews

✦ No before and after photos

✦ No treatment photos or videos with S4 medications

✦ No price lists

✦ No brand names

✦ No service list or treatment menu

✦ Changes in booking systems for treatments we perform

 

The changes aim to prevent the promotion of cosmetic injectables in a way that may encourage unnecessary or unsafe use. These changes reflect a growing emphasis on consumer safety. 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.

https://www.tga.gov.au/news/media-releases/referring-cosmetic-injectables-advertising

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