AHPRA, TGA, and the New Era of Cosmetic Marketing

AHPRA, TGA, and the New Era of Cosmetic Marketing: Why Compliance Is Now Your Strongest Brand Advantage
The cosmetic and aesthetic industry in Australia has entered a new era, one defined by heightened regulation, digital transparency, and consumer protection.
With recent AHPRA and TGA advertising reforms, every clinic, injector, and aesthetic practice must think beyond “visibility” and focus on ethical, compliant marketing that builds trust.
At GrowthGen Digital, we’ve seen too many clinics lose credibility, and ad accounts — simply because they didn’t fully understand what compliance really means in today’s digital space.
Let’s break it down.
Understanding the New AHPRA Guidelines for Cosmetic Procedures
AHPRA (Australian Health Practitioner Regulation Agency) released updated advertising guidelines for cosmetic surgery and procedures in 2023–2024, aimed at protecting patients from misleading or unsafe promotions.
The key focus areas include:
- No testimonials or reviews relating to clinical outcomes (even on social media)
- No “before and after” imagery that implies guaranteed results
- No time-limited offers or discounts that may pressure consumers into making quick decisions
- No claims of superiority or comparison between practitioners or devices
- No use of photos, emojis, or language that trivialises procedures (e.g., “lunchtime lift,” “no downtime miracle”)
- Mandatory disclaimers and expectation management — results vary, and consultation is essential
TGA Rules: What You Can and Can’t Say About Therapeutic Goods
The Therapeutic Goods Administration (TGA) regulates all advertising of medical devices, injectables, and prescription-only products. This includes Botulinum toxin type A, dermal fillers, and any branded injectables.
Under the TGA Advertising Code 2024, it’s prohibited to:
- Mention brand names like Botox®, Dysport®, or Juvederm® in public advertising
- Use therapeutic claims such as “treats wrinkles” or “erases fine lines”
- Display images that suggest a therapeutic outcome
- Link your website to supplier or manufacturer pages promoting those products
Instead, marketers must use generic, descriptive phrasing like “anti-wrinkle treatments” or “cosmetic injectables,” paired with clear disclaimers and expectation-based language (e.g., “may help soften the appearance of fine lines”).
The Digital Grey Zone: Meta and Google Ads
Meta (Facebook/Instagram) and Google have tightened ad review algorithms to detect medical and cosmetic content violations.
Even subtle breaches — like using a “before and after” in a carousel or mentioning “Botox” in hidden metadata — can lead to disapproval or account restrictions.
To remain compliant and effective:
- Use education-based ad content (“Learn about skin rejuvenation options”) rather than promotional promises
- Avoid trigger words that imply medical procedures or outcomes
- Include disclaimers directly within creative or ad copy
- Focus on brand storytelling, safety, and consultation-based calls to action
GrowthGen Digital continuously monitors these evolving platform rules to ensure our clients’ campaigns stay live — and compliant.
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As your budget progresses and evolves, continue referring to your SMART objectives. Stay focused and remember your goals – they will always inform what your next step will be!

