In January this year, the Therapeutic Goods Administration of Australia, aka the TGA, surprised the non surgical cosmetic industry with the news that we are no longer allowed to use common terms to describe some of the services we provide, using the drugs used in those services. Medical aesthetics can no longer use certain terms and those terms will be going away?

What Kind of Terms are Changing in Medical Aesthetics?

Terms that you commonly associate with the services you receive from a medical aesthetics practitioner are no longer able to be used in advertising, information on websites, and other key places.

• Anti wrinkle treatment
• Dermal filler
• Biostimulatory filler
• Fat dissolving injections

You get the idea.

What Do the New TGA Guidelines Say?

It sent the industry into a panic and the TGA took its guidance offline to await confirmation. As of 7th March 2024 it had finalised its guidelines, and the new changes will go through, effective immediately.

What do they say in essence?

Historically, the TGA has allowed indirect references to prescription medicines to be referenced in advertisements related to cosmetic health services. This was allowed only in the context of promoting the service and only by using generic non-product specific terms such as ‘wrinkle reducing injections.’ Express references to products or ingredients themselves, such as ‘Botox’ or ‘botulinum toxin’, were not permitted. The TGA considered this a pragmatic approach which would allow cosmetic clinics who offered these services to differentiate themselves from those that did not.

It goes into further details, the gist of which is essentially:

• we are no longer allowed to refer to those terms as they allude to the use of prescription drugs
• we are no longer allowed to use before/ after photos that suggest the use of prescription drugs eg before photo with someone frowning, and after photo without the frown; or a before photo of someone with thin lips and after photo with plumper lips etc

Why is the TGA doing this?

Recently, the TGA has observed that clinics and health services in other industry areas are advertising the availability of prescription medicines, usually by referring to a class of goods (for example ‘weight loss injections’, ‘medicinal cannabis’ or ‘nicotine vaping products’). The TGA has interpreted that promoting a health service in this way is also an advertisement for a therapeutic good that refers to prescription medicines, which is unlawful.

The update aligns with the focus of other regulators on health professionals performing non-surgical cosmetic procedures and acknowledges the increasing vulnerability of Australians influenced by advertising in the cosmetic space. Prescription only medications carry higher risks than goods available for self-selection. Decisions about treatments that involve the use of prescription medicines should only be made by a health professional in consultation with each individual patient.

In brief, as with all other means of prescription medications, a face to face consultation is the first step to addressing a concern in collaboration with your medical professional/ doctor to then determine next steps, treatment and whatever drugs that might involve.

As you can imagine, this has the industry in a tizzy all over again.

Do the TGA Guidelines Change the Medical Aesthetics Approach at Skin Essentials?

At Skin Essentials, we’ve never advertised drugs by prices, nor by before/ after pictures such as above. We take a holistic full face approach to the face in front of us at a paid-for, non redeemable consultation designed with one thing in mind :

• understanding and addressing your aesthetic concerns
• determining if they can be helped or if you need another expert eg a plastic surgeon
• determining if we are likely to work well together ie a good fit
• determining if you have any vulnerabilities that make you unsuitable for cosmetic work or have unrealistic expectations
• determining the timeframe to get you results
• determining the cost of those results, which is significant
• determining if you are in a position, psychologically as well as financially to commit to the process as outlined

If we tick all those boxes above, then we start.

If you or I cannot tick any of the list above, then we don’t start, but you’ve had some idea as to what the cause of your concerns is, what is needed to correct them if/ when you are ready to begin.

So from our point of view, not much will change to our processes at Skin Essentials.

What *will* change is the ban on educating the general public on social media and the stern limitation of terms I can use to do this.

Media from the USA and UK and other parts of the world continue to flood our feeds, with drug names and explicit videos of procedures. I used to use this for educational purposes but I will no longer be able to do this as this would be a violation of the TGA rules.

While the goal and aim of the TGA is to stop unscrupulous operators from enticing and luring vulnerable people into medical aesthetics, often from a very young age, the reality is that since these changes were announced, the rogue operators, who continued to operate during Covid lockdowns, continue to post and use the terms “anti wrinkle”, “dermal filler” “nose filler” “biostimulatory filler” and more.

As I’ve said before, I suspect they see pesky fines and disciplinary action as the price of doing business.

As a small business, I can’t afford to do this nor do I want to.

One of my strongest stances at Skin Essentials is our ethics and our values based approach to patient care. That won’t change in coming weeks and months as we pivot to find a new way to educate people without using terminology illegally.

In the meantime, we ask our current patients to help others find us by leaving us honest feedback of their experiences with us in clinic given social media is being heavily censored going forward to help us stay in business.

Thank you for your ongoing support and we hope to see you in clinic soon!