New AHPRA guidelines ban ‘tox’, ‘baby botox’ hashtags as regulators target cosmetic injectables advertising, warns ClearAds Director Alison Lee.
What’s happening: New AHPRA guidelines that came into effect on 2nd September 2025 have fundamentally changed how cosmetic injectables can be advertised, with regulators actively targeting non-compliant businesses, agencies, and social media influencers.
Why this matters: With the cosmetic injectables industry valued at $4.1 billion and growing 19.3% annually, the compliance crackdown affects thousands of businesses that must immediately audit their advertising or face severe penalties.
Australia’s cosmetic injectables boom has hit a regulatory wall. What began as rapid industry expansion has collided with mounting compliance failures, triggering the most significant advertising restrictions the sector has ever faced.
The collision was inevitable. In the last financial year alone, the Therapeutic Goods Administration requested the removal of nearly 13,500 advertisements from online platforms, revealing the scale of non-compliance across digital media in an industry that has grown faster than its regulatory framework could manage.
Rules take effect
The new Guidelines for advertising higher risk non-surgical cosmetic procedures came into effect on 2 September 2025, fundamentally changing how businesses can promote cosmetic treatments. These AHPRA guidelines clarify how regulators will interpret and enforce existing advertising regulations under the National Law, extending beyond health practitioners to include marketing agencies and social media influencers.
The restrictions are comprehensive and immediate. Under both existing TGA law and the new AHPRA guidelines, it is now illegal to directly or indirectly advertise prescription-only injectables through product names like “wrinkle-reducing injections” or “dermal fillers,” brand names such as Botox, Juvederm, or Restylin, nicknames including “tox,” “baby botox,” “brotox,” or “lip flicks,” hashtags referencing any of the above, or advertising treatment prices.
The guidelines outline what is considered misleading or unlawful, including the use of testimonials, and promotional language that may breach legal obligations.
Enforcement intensifies rapidly
Regulators have made their intentions clear: they’re actively seeking to make examples of those who breach the new rules. “With the new AHPRA guidelines now in effect, the time for practitioners and marketers to act is no longer ‘before September,’ but right now,” says Alison Lee, Director of ClearAds.
“Regulators are taking a firm stance, and businesses that fail to align their advertising with these rules are at risk of a public compliance action,” Lee warned.
The enforcement extends beyond cosmetic injectables. The TGA is simultaneously taking action against unlawful advertisements for medicinal cannabis and weight-loss treatments, signalling a broader regulatory shift towards stricter advertising oversight across therapeutic goods.
This regulatory environment mirrors broader compliance challenges facing Australian businesses as privacy laws also undergo major reforms, creating a complex landscape where multiple regulatory changes demand immediate attention.
Language gets restricted
The new guidelines have effectively rewritten the vocabulary of cosmetic marketing. Terms like “Dermal fillers” and “Anti-wrinkle Injections” are no longer allowed, and the use of patient Before and After images promoting these injectables will be restricted, as will be the use of any business names containing words that promote their use.
Social media poses particular challenges. Hashtags that were commonplace in cosmetic marketing – #botox, #fillers, #antiaging – now represent compliance violations. Even indirect references through coded language or suggestive imagery can trigger regulatory action.
The impact reaches beyond individual posts to entire business models. Influencers who built followings around cosmetic content must completely restructure their approach, while clinics face the challenge of maintaining visibility in a highly competitive market without using the terminology that previously drove customer engagement.
Marketing agencies working with cosmetic clients face perhaps the steepest learning curve. Campaign strategies developed over years of industry growth must be completely reimagined to comply with restrictions that fundamentally change how services can be promoted.
Compliance becomes critical
The regulatory shift places immediate pressure on every business touching the cosmetic injectables space. “Our message is clear: businesses must audit their social media, websites, and influencer content immediately,” Lee emphasised.
ClearAds, a longstanding member of the Therapeutic Goods Advertising Consultative Committee, reviews advertising material across all platforms to ensure compliance with the Therapeutic Goods Advertising Code. Lee notes that using compliance services “can help demonstrate to the regulator a genuine willingness to comply and prevent costly mistakes.”
The urgency stems from regulators’ stated intention to make public examples of non-compliant businesses. Unlike gradual policy implementation, these guidelines demand immediate, comprehensive changes to existing marketing approaches.
For an industry valued at $4.1 billion with projected annual growth of 19.3% through to 2030, compliance failures could prove catastrophic for individual businesses while potentially constraining broader sector growth.
The challenge extends beyond simple language changes. Businesses must develop new ways to communicate value propositions, differentiate services, and maintain customer relationships within a framework that eliminates much of their traditional marketing vocabulary.
The September implementation date marked not just new rules, but a fundamental reset of how Australia’s cosmetic injectables industry can operate in the digital marketing age.
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