If you run a cosmetic clinic, dermal practice, or injectable business, the words you use in your marketing matter just as much as the images you share.
In cosmetic advertising, even small wording choices can:
- create unrealistic expectations
- unintentionally imply prescription-only medicines
- downplay risk
- or make a post misleading under Australian law
That can expose your clinic to complaints, regulator scrutiny, or compliance action under:
- AHPRA (regulated health services advertising)
- TGA (therapeutic goods advertising)
- ACL (misleading or deceptive conduct laws)
This guide breaks down high-risk words, commonly flagged phrases, and safer alternatives, in plain English.
Why are certain words restricted?
There is no official “banned words list.”
Instead, regulators assess advertising based on:
✘ whether it creates unrealistic expectations
✘ whether it implies guaranteed results
✘ whether it suggests a product or procedure is risk-free or superior
✘ whether it turns education into unlawful promotion
✘ whether it implies promotion of a prescription-only medicine
✘ whether the overall impression misleads consumers
A word becomes non-compliant based on context, evidence, and the impression it creates, not because it appears on a fixed list.
High-Risk Words
1. Guaranteed results
Why this category is high-risk:
Regulators prohibit advertising that creates unrealistic expectations, implies certainty of outcome, or guarantees success. In cosmetic services, outcomes vary between individuals. Absolute claims are rarely defensible.
High-risk wording includes:
- guarantee / guaranteed
- permanent
- erase
- eliminate
- reverse ageing
- transform instantly
- instant results
- cure
- fix
- perfect
- miracle
- 100% results
- “works every time”
Why regulators scrutinise this:
- ACL: Absolute outcome claims must be true and provable. Most cosmetic outcomes cannot be guaranteed.
- AHPRA: Advertising must not create unreasonable expectations of benefit.
- TGA: Advertising must be accurate, balanced, and not misleading about benefits or risks.
2. “Safe” claims
Why this category is high-risk:
All medical and cosmetic procedures carry some level of risk. Advertising that suggests a treatment is risk-free or harmless can mislead consumers or downplay important safety information.
High-risk wording includes:
- safe
- safest
- risk-free
- no downtime
- no side effects
- painless
- zero pain
- gentle but powerful
- non-toxic (unless ARTG indication supports it)
Why regulators scrutinise this:
- TGA: Advertising must not imply a therapeutic good is completely safe or without risk.
- AHPRA: Claims that downplay risk or exaggerate safety may mislead.
- ACL: Safety claims must be accurate and substantiated.
Note: Context and evidence matter. Even factually correct claims can mislead if they minimise risk.
3. Prescription-Only Medicine References (Injectables)
Why this category is high-risk:
Prescription-only medicines (Schedule 4) cannot be advertised to the public. Wording that directly or indirectly identifies a specific injectable product, even through slang, measurements, or promotions, may breach the TGA Advertising Code.
High-risk wording includes:
- “anti-wrinkle” used as a product noun (e.g. “anti-wrinkle specials”)
- anti-wrinkle units
- lip filler deals
- 1ml / 2ml
- top-ups
- “muscle relaxant day”
- product-coded nicknames
- phrases that, in context, clearly point to an injectable medicine
Why regulators scrutinise this:
If a consumer can reasonably identify a specific prescription-only product from your wording, it may be considered unlawful advertising, even if the brand name is not used.
Context is critical: imagery, hashtags, pricing, and captions are assessed together.
4. Comparative or “Superiority” claims
Why this category is high-risk:
Comparative claims must be truthful, evidence-based, and able to be substantiated. Words like “best” or “most advanced” are often considered misleading unless supported by objective, verifiable evidence.
High-risk wording includes:
- better than other clinics
- more effective
- safer
- fastest results
- longest-lasting
- premium results
- superior outcomes
- best results
- best injector
- most advanced
Why regulators scrutinise this:
- ACL: You must be able to prove comparative claims.
- AHPRA: Advertising must not be misleading or create unjustified expectations.
If you cannot objectively prove it, avoid stating it.
5. Emotional manipulation or vulnerable consumer targeting
Why this category is high-risk:
Advertising must not exploit vulnerability or target consumers’ insecurities in a way that pressures them into treatment.
High-risk wording includes:
- fix your face
- erase insecurities
- get your confidence back
- glow-up guaranteed
- look 10 years younger instantly
- “anti-ageing cure”
These phrases can create unrealistic expectations or apply emotional pressure.
6. Dramatic Outcome Language in Before/After Content
Why this category is high-risk:
Before/after advertising is already heavily scrutinised. Adding dramatic or exaggerated language increases the risk of creating unrealistic expectations.
High-risk wording includes:
- dramatic transformation
- lifted
- sculpted
- snatched
- tightened (where it implies medical-grade energy devices)
- rejuvenation guaranteed
It’s not just the word, regulators assess the overall impression created by text, images, editing and context combined.
What you can say instead
Lower-risk wording (still needs to be true, typical, and within ARTG indications where relevant)
✔ may help improve
✔ supports skin health
✔ designed to target
✔ assists in maintaining
✔ helps relieve mild X (only if ARTG supports it and mandatory statements are included where required)
✔ individual results vary
✔ always follow directions for use (mandatory for devices/medicines)
Lower-risk wording (must still be accurate, evidence-based and appropriate to context)
✔ may help improve
✔ supports skin health
✔ designed to target
✔ assists in maintaining
✔ helps relieve mild X (only if consistent with ARTG and mandatory statements are included where required)
✔ individual results vary
✔ always follow directions for use (where required for therapeutic goods)
✔ consultation required
✔ suitability varies
✔ risks and benefits discussed during consultation
✔ results depend on individual factors
Important: Even low-risk wording can breach the law if the overall impression is misleading.
Lower-risk wording under ACL principles:
(Must still be accurate, evidence-based and not misleading.)
✔ realistic outcomes
✔ cosmetic only (if accurate and not downplaying medical risk)
✔ results depend on individual factors
✔ evidence-based skincare (if supported by credible evidence)
✔ professionally delivered cosmetic services
EXAMPLES
✘ High-risk and likely non-compliant
“Erase wrinkles instantly with our injectable special!”
Why this is problematic:
“erase” implies a guaranteed outcome
– “instantly” suggests certainty and exaggeration
– “special” may be considered an inducement
– “injectable” + promotional language may imply advertising a prescription-only medicine
– creates unrealistic expectations of benefit
Compliance depends on the overall impression, but wording like this would attract regulatory scrutiny.
✔ Lower-risk example (still context dependent)
“Book a consultation to discuss wrinkle-reducing treatment options with our registered team. Individual results vary. This is general information only.”
Why this is lower risk:
– focuses on consultation rather than promising outcomes
– avoids guarantees or exaggerated benefit
– does not name or promote a specific prescription-only medicine
– avoids comparative or superiority claims
Important: Compliance depends on the overall context, including images, hashtags, pricing and surrounding content. No single sentence guarantees compliance.
Hashtag Rules & Guides
Want a practical breakdown of high-risk hashtags, safer alternatives and platform-specific compliance risks?
Want the full compliance Toolkit?
Get the Hashtag Rules & Compliance Guide inside the
AHPRA & TGA Marketing Compliance Pack for Cosmetic Injectors
✔ high-risk words and phrases guide
✔ high-risk hashtag categories
✔ safer alternative wording
✔ image compliance rules
✔ caption templates
✔ keyword risk checklist
✔ full posting compliance checklists
✔ platform-by-platform guidance
Protect your clinic.
Protect your registration.
Protect your business.
About the Author
Riz is the Founder & Director of Foundd Legal, a lawyer with 20+ years’ experience and a long history of building online and ecommerce businesses.
She helps creatives and online business owners protect and grow their businesses with clear, practical legal tools that actually make sense.
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Disclaimer
We do our best to keep this content accurate and up to date, but laws change, interpretations evolve, and the internet isn’t perfect. Occasionally, information may be outdated or contain errors.
This content is for general information only and isn’t legal advice. If you choose to rely on it, you do so at your own discretion. For advice specific to your business, you’ll need support tailored to your situation.
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