Anti-wrinkle injections. Dermal fillers. Those were the safe substitutes for a decade. They are no longer expressly permitted, and the guidance now says to advertise the consultation rather than the treatment. Most Australian aesthetics advertising has not caught up.




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Most cosmetic injectables contain prescription-only substances, and under the Therapeutic Goods Act those cannot be advertised to the public. For years the workaround was a generic phrase rather than a brand name, and the TGA permitted it.
That changed. The TGA's position is now that it no longer expressly permits references to terms such as wrinkle reducing injections or dermal fillers where those terms would lead a reasonable consumer to understand the intention is to promote a prescription medicine. The guidance explicitly extends to acronyms, nicknames, abbreviations and hashtags. It also declines to publish a list of acceptable substitute terms, which is uncomfortable but consistent: there is no magic word, because the test is what the consumer understands.
The one piece of positive guidance offered is to advertise the consultation rather than the treatment. That is a genuinely different campaign architecture from the one nearly every Australian aesthetics clinic is running.
This is the lookup nobody publishes, and it is the difference between a campaign that runs and one that creates an exposure. The line is drawn by whether the product is a scheduled medicine or a device.
| Product or modality | Regulatory status | Can it be named in advertising |
|---|---|---|
| Botulinum toxin, all brands | Prescription only medicine | No |
| Hyaluronic acid fillers | Prescription only medicine | No |
| Poly-L-lactic acid injectables | Prescription only medicine | No |
| Injectable hyaluronic acid bio-remodellers | Prescription only medicine | No |
| Polynucleotide skin treatments | Class III medical device, not scheduled | Yes |
| PDO threads | Class III medical device, not scheduled | Yes, where listed on the ARTG |
| Lasers, IPL, RF, ultrasound devices | Medical devices | Yes, subject to the advertising code |
| Platelet rich plasma | Outside scope where no scheduled substance is involved | The TGA calls this complex. Take advice |
The practical consequence is that a clinic's advertisable menu and its revenue menu are different documents. Devices, threads and energy treatments can be named and priced. The highest frequency, highest revenue service cannot be named at all.
Australian monthly search volumes, Q3 2026. This asymmetry is the central strategic problem of the category and we have not seen another page state it.
Source: Medical Marketing Group Australian benchmarks, Q3 2026, from Google keyword planning data.
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