Cosmetic advertising is under fire: What agencies must know before September 2
On September 2, new guidelines for the lawful promotion of cosmetic services such as injectables, PRP treatments, thread lifts, and fillers, will take effect.
Alison Lee, director of advertising review and classification service ClearAds, explains what rules agencies and creators in the industry must be across in the next few weeks.
Australia’s $4.1 billion cosmetic injectables industry is in the midst of a marketing reckoning. With growth forecast to surge by more than 19% annually through to 2030, non-surgical aesthetic procedures are increasingly being promoted across social media, digital platforms, and influencer channels. Come September 2, advertising in this category will require much more than creative flair.
That’s the day new Australian Health Practitioner Regulation Agency (AHPRA) guidelines take effect, providing greater clarity of what constitutes lawful promotion of cosmetic services such as injectables, PRP treatments, thread lifts, and fillers. These updates follow a year in which the Therapeutic Goods Administration (TGA) requested the removal of nearly 13,500 non-compliant ads; a clear signal that enforcement is escalating across the board.
While these regulations are well known to health professionals, they’re still underappreciated within media and marketing circles. That’s a dangerous blind spot. Because under Australian law, anyone who is responsible for the promotion of prescription-only treatments, be it agencies, influencers or publishers could be in the frame.
A shifting landscape for agencies and creators
At ClearAds, we review thousands of ads, social posts, and influencer campaigns every month. What we’re seeing is a persistent gap between aesthetic sector compliance obligations and the current digital marketing playbook. This isn’t about deliberate misconduct, it’s largely a matter of industry practice outpacing regulatory understanding.
Common breaches include:
- Use of restricted product or brand names (e.g. Botox, dermal fillers, “wrinkle-reducing injections”)
- Promotional nicknames (e.g. “tox”, “baby botox”, “lip flip”, “brotox”)
- Hashtags referencing the above
- Publishing treatment prices or inducements
- Testimonials, before-and-after photos, or influencer “results” videos
Even the casual use of emojis or beauty jargon in a sponsored caption may constitute indirect promotion of prescription-only products, something expressly prohibited by the law.
And yes, even when influencers include a “not medical advice” disclaimer or frame content as “personal experience”, it can still fall within the definition of advertising.
New guidelines are coming.
Why September 2 matters
While the core legislation hasn’t changed, the AHPRA guidelines landing in September clarify how existing rules will be interpreted moving forward. They stem from a broader review into the cosmetic sector, which found that many clinics and promoters were using lifestyle content to overpromise results, exploit appearance-based insecurities, or circumvent advertising regulations altogether.
The new guidelines put creatives on notice: if you’re involved in the promotion of these services, you are responsible for getting the messaging right.
The enforcement gap is closing
Last month, The Daily Telegraph reported on the disparity between how media outlets and influencers are treated in the enforcement landscape. While publishers like News Corp have been fined for non-compliant advertising, many social creators still operate in a grey zone. But that won’t last.
The TGA has already blocked over 150 websites and removed thousands of digital ads. Now, regulators are increasingly turning their attention to social media and influencer marketing – often the frontline for aesthetic advertising.
Agencies that engage creators, write ad copy, or publish content on behalf of cosmetic clients must ensure every output is compliant. If not, they risk financial penalties, public naming, reputational fallout, and even client legal exposure.
What media and marketing teams should do now
Audit all existing content – Review all current client campaigns, website copy, paid social ads, email funnels, and influencer collaborations. Remove banned terminology, testimonials, and brand names linked to prescription-only treatments.
Educate your teams and talent – Your content creators, designers, freelancers, and talent managers need to understand the new rules. Compliance isn’t just a clinical issue, it’s now squarely a creative and content responsibility.
Use compliance services – Services like ClearAds exist to help media teams pre-review content and ensure alignment with the Therapeutic Goods Advertising Code (TGAC).
Update contracts and briefs – Agency agreements with influencers and content creators should now include compliance responsibilities, approved messaging, and rules around tagging, terminology, and visuals. If you haven’t updated these since last year, it’s time.
Plan for the long game – Don’t wait until a client is penalised to take compliance seriously. Aligning with the law now not only protects your agency, it shows leadership and integrity in a space that’s rapidly growing.
Alison Lee
Marketing in a regulated category isn’t new, but it’s evolving
This isn’t the first time a booming sector has caught the eye of regulators – therapeutic goods, supplements, weight-loss treatments, and even vaping have all faced increasing advertising scrutiny.
But cosmetic injectables are unique in that they occupy a crossover between clinical medicine and lifestyle marketing. That makes them especially tricky to get right and incredibly risky to get wrong.
For marketing professionals, this is not about stepping back from the space. It’s about stepping up your strategy: learning the rules, leading with education, and creating compelling content that builds trust instead of blurring legal lines.
Compliance in cosmetic advertising isn’t a constraint, it’s an opportunity to raise industry standards, earn consumer trust, and differentiate responsible operators from risky ones.
The clock is ticking. Now’s the time to get your house in order.
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