Plus: The simple fixes every clinic can apply today
Social media is the #1 way cosmetic injectors attract clients, and it’s also the #1 place clinics accidentally break the law.
The Therapeutic Goods Administration (TGA) actively monitors Instagram, Meta, TikTok and Google for unlawful advertising of prescription-only injectables, medical devices and therapeutic goods.
The scary part?
Most breaches happen because no one has ever explained the rules in plain English.
This blog does exactly that. By the end, you’ll know the biggest mistakes injectors make, and the exact steps to fix them immediately.
Mistake 1: Naming (or hinting at) prescription-only products
This is the single most common breach in Australia.
Under the TGA Advertising Code, you cannot advertise or promote prescription-only products.
This includes:
✘ Botox®
✘ Dysport®
✘ Xeomin®
✘ Juvederm®
✘ Restylane®
✘ Sculptra®
✘ Profhilo®
✘ SkinVive®
✘ Radiesse®
✘ ANY S4 injectable, by brand or active ingredient
This includes:
- captions
- hashtags
- packaging shown in images
- videos with visible labels
- training content
- treatment room photos with boxes in the background
- “we use brand here” posts
- “1ml of brand” before/after shots
If the public can tell what you injected → it’s a breach.
✔ The Fix
Use generic terms only, such as:
- anti-wrinkle treatments
- dermal filler treatments
- collagen-stimulating treatments
- skin rejuvenation
- volume restoration
- hydration-boosting treatment
- bio-remodelling treatments
(only if you do NOT name or hint at the actual product)
Want legally safe examples? They’re inside the Compliance Pack.
Mistake 2: Posting before-and-after photos of injectable treatments
Before/after images are powerful, but for injectors, they’re also a massive TGA breach.
Why?
Because they imply what was used.
Even without naming a product, before/after photos often reveal:
- anti-wrinkle injections
- lip filler
- dermal filler
- skin boosters
- fat-dissolving injectables
- PRP or biostimulators
- thread lifting results
- medical-grade device outcomes
Under the TGA Code, anything that shows or strongly implies a prescription-only treatment is considered advertising, which is prohibited.
✔ What you CAN post
Before/after is allowed ONLY for non-medical, non-prescription cosmetic services, such as:
✔ chemical peels
✔ microneedling (cosmetic, not medical)
✔ LED facials
✔ cosmetic facials
✔ topical skincare routines
✔ non-medical exfoliation treatments
✔ cosmetic skin improvements that do not imply a device or prescription product
All of these must still follow ACL rules (no exaggerated or unrealistic claims).
Mistake 3: Using banned phrases that make therapeutic claims
Words and phrases that imply certainty, safety or guaranteed outcomes are banned under the TGA Code and ACL.
Clinics commonly (and accidentally) post:
✘ “Erase wrinkles instantly”
✘ “No downtime, pain-free, risk-free”
✘ “Guaranteed results”
✘ “Safe and effective”
✘ “Best treatment on the market”
✘ “Fastest results”
✘ “Anti-ageing cure”
✘ “Filler that never migrates”
✘ “Zero side effects”
These statements are unlawful whether you post them yourself OR they appear in:
- captions
- text overlays
- talking to camera
- infographics
- comments left by clients
- hashtags
- testimonials
✔ The Fix
Use neutral, factual, non-therapeutic phrasing like:
✔ “may assist”
✔ “supports skin health”
✔ “can improve the appearance of…”
✔ “a consultation is required to assess suitability”
✔ “individual results vary”
✔ “general information only, not medical advice”
The full approved wording list is included in the Compliance Pack.
Mistake 4: Posting testimonials that mention results
If you have an AHPRA-registered practitioner (nurse or doctor), AHPRA prohibits all testimonials, even “experience only” ones.
But even if you’re not AHPRA-regulated, TGA and ACL ban testimonials that mention or imply:
✘ anti-wrinkle results
✘ filler outcomes
✘ speed of results
✘ medical claims
✘ comparisons (“best in Brisbane”)
✘ guaranteed success
✘ pain-free procedures
✘ safety claims
You must delete any comments that do this on your posts, yes, even innocent ones like:
“My anti-wrinkle always works so fast here!”
“My filler never migrates with you!”
“You fixed my pigmentation!”
These are legally considered advertising.
✔ The Fix
You can only share testimonials about:
✔ professionalism
✔ friendliness
✔ education
✔ cleanliness
✔ environment
✔ customer service
✔ how supported the patient felt
If the practitioner is AHPRA-registered → you cannot post testimonials at all.
Mistake 5: Offering discounts, giveaways or “specials” on injectables
This is a major TGA AND AHPRA breach.
You cannot promote or encourage the use of prescription-only cosmetic treatments through:
✘ “$50 off anti-wrinkle this week”
✘ “Lips 1ml for $399”
✘ “Buy now, get top-up free”
✘ “Win 1ml filler!”
✘ “Free anti-wrinkle with facial package”
✘ “Black Friday injectable specials”
✘ loyalty programs involving injectables
These are considered inducements, illegal for regulated health services.
✔ What you CAN promote
Allowed:
✔ skincare gift packs
✔ LED sessions
✔ facials
✔ non-medical cosmetic treatments
✔ consultation vouchers
✔ education events
Still must follow ACL (truthful, accurate, realistic).
Mistake 6: Using the wrong images
TGA and ACL regulate imagery just as strictly as captions.
Unlawful images include:
✘ syringes
✘ needles
✘ injection clips
✘ holding up vials or boxes
✘ before/after of injectables
✘ visible brand labels
✘ device handpieces that imply medical-grade functions
✘ extreme or unrealistic results
✘ AI-created “perfect skin” transformations
Your imagery can breach the law even if your caption is compliant.
✔ What you CAN use
✔ consultation photos
✔ clean clinic environment shots
✔ practitioners (with reg numbers when promoting clinical services)
✔ generic skin diagrams
✔ LED, facials, microneedling (non-medical)
✔ educational slides
✔ natural, realistic results
Mistake 7: Forgetting that comments also count as advertising
This is a HUGE one and most clinics have absolutely no idea.
If someone comments:
“My lips look amazing!”
“My anti-wrinkle lasts longer with you!”
“You’re the best injector!”
You must delete it.
You are legally responsible for user-generated comments on your business posts, under both TGA and AHPRA.
✔ The Fix
Set up a SOP (standard operating procedure) on what your process will be for moderating comments and ensure staff or contractors who manage your socials follow that process.
Mistake 8: Mixing up AHPRA, TGA and ACL or not knowing which one applies
Here’s the simple version:
TGA applies when you promote products or anything used for a therapeutic purpose.
Injectables, devices, vitamins, skincare with claims, sunscreens, all trigger TGA.
AHPRA applies when a nurse/doctor is involved.
If a regulated health service is provided → AHPRA rules also apply.
ACL applies to absolutely everyone.
Doesn’t matter what you offer, every claim must be truthful and not misleading.
Most clinics break rules because they don’t realise all three apply simultaneously.
The Compliance Pack helps you understand all of this.
How to Fix ALL These Mistakes (Without Needing a Law Degree)
This is exactly why I created the AHPRA & TGA Marketing Compliance Pack for Cosmetic Clinics the first of its kind in Australia.
It includes:
✔ Social Media Posting Policy
✔ Ads Compliance Guide (Meta + Google)
✔ Google My Business Guide
✔ Website Compliance Guide
✔ Email Marketing Guide
✔ Print/TV/Radio Guide
✔ Collab & Influencer Compliance Guide
✔ Hashtag Rules
✔ Mandatory Wording Templates
✔ AHPRA Compliant Practitioner Wording
✔ “What You Can Say Instead” lists
✔ Image & Before/After rules
✔ Comment Moderation SOP
✔ Handy checklists in every guide
✔ Full Master Guide consolidating all rules
Plus: The full pre-recorded workshop (value $800) as a pack add-on for just $195.
This is the compliance system every clinic has been begging for.
Ready to stop guessing and start posting legally?
Get the AHPRA & TGA Marketing Compliance Pack for Cosmetic Injectors here
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***Disclaimer. Please read!!***
This article is for general information purposes only and should be used solely as general guidance. It does not and is not intended to represent legal advice or other professional advice.
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