The TGA has ordered clinicians not to use terms such as ‘anti-wrinkle injections’ or ‘dermal fillers’ in advertisements, arguing that these generic non-product terms breach legislation against promoting prescription medicines rather than simply a health service.

In updated rules, the TGA says advertisements should now only focus on the type of service offered, such as ‘our clinic can provide consultations about reducing wrinkles’.

The watchdog said its updated guidance applied to any terms that acted as a substitute for direct references to prescription-only drugs such as ‘plant-based medicine’, ‘wrinkle reducing injections’ or ‘weight loss injections’.

This included business names that might indirectly promote a therapeutic good, such as those with ‘medical cannabis’ or ‘injectables’ in their names.

“To ensure that your advertisement for a health service is not also considered an advertisement for therapeutic goods, it is best not to refer to any therapeutic goods used in the delivery of the service in the advertisement,” the TGA said in guidance published on 7 March [link here].

“It should be clear that the customer is being offered a health-practitioner-led consultation and that, depending on the outcome of the consultation, this may or may not lead to the provision of a prescription.”

Historically, the TGA has allowed indirect references to prescription medicines to be referenced in advertisements related to cosmetic services, although references to products or ingredients such as ‘Botox’ were already banned.

However, the TGA said it now had to clarify its rules because clinics and health services in other areas such as those providing weight loss, vaping and medical cannabis services had been advertising the availability of prescription medicines unlawfully.

The crackdown on cosmetic services aimed to resolve “any inconsistency in interpretation across industry areas”, the regulator said.

The TGA statement warns that the scope of promotion is not limited to advertising content in print, online and broadcast media, but can include articles, posters, notices, videos as well as ‘electronic transmissions and material posted on the internet’.

Caution is also need in potentially advertising a therapeutic good  in point-of-sale materials, leaflets, booklets and product reviews, it advised.

However, the TGA’s ban has been met with some criticism from cosmetic doctors and plastic surgeons with the Australasian Society of Aesthetic Plastic Surgeons suggesting its members had been ‘blind-sided’ by the new guidance.

“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,” said Brisbane plastic surgeon Dr Lily Vrtik, who is also an ASAPS board member, in a statement [link here].