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In a letter sent by the Therapeutic Goods Administration, a branch of the Australian Department of Health and Aged Care, new restrictions were announced that will make it even more difficult for medical aesthetic providers to market their products online.
The broad TGA rule being applied is that “It is not legal to influence consumers about the use or supply of prescription medicines through advertising.”
The changes technically apply to all Schedule 4 drugs, but for the cosmetic industry, injectable fillers and neuromodulators will be the most impacted as they fall under the umbrella of “prescription medications.”
Here is a list of some of the key cosmetic substances that are considered Schedule 4:
- Botulinum toxins
- Hyaluronic acids
- Calcium hydroxyapatite
- Poly-L-lactic acid
- Collagen
The letter specifically states that phrases “wrinkle reducing injection,” “anti-wrinkle injections,” and “dermal fillers” will no longer be permissible under the changes.
It is reasonable to assume that, under these changes, phrasing such as “muscle relaxants” or “muscle relaxers” – phrases often used to avoid the previous restrictions on the mention of products like “Botox” specifically – will soon also fall under scrutiny and no longer be compliant.
The TGA does provide the following example of language that is compliant with the new regulations:
“Our clinic can provide consultations on reducing the appearance of wrinkles.”
What Does This Mean for My Marketing?
The changes outlined by this letter technically went into effect on December 18, 2023, when the aforementioned terms were removed from TGA Guidance documents, but as of now, the organization has not published revised guidance documents but says they plan to do so by “mid to late January.”
Unfortunately, even though no guidance documents have been provided, your practice is still on the line to stay compliant with these new rulings and regulations.
Here are some potential parts of your marketing program that are likely going to be impacted:
Website Content
It is possible that the mere existence of pages dedicated to providing information about injectable fillers, neuromodulators, and other Schedule 4 drugs could be against regulations. This means you may need to figure out an entirely new website strategy.
Workaround:
If it does come to pass that providers can no longer mention these treatments in any capacity, it is still possible to engage in digital marketing through the education of conditions instead of products.
For example, this means that instead of marketing “wrinkle relaxants” on your website, it would be beneficial to go all in on the creation of content that explains what wrinkles are, how they develop, why they develop, what the different types are, and other pertinent and useful information to someone who is frustrated with the appearance of wrinkles.
Throughout your content, use compliant calls to action to turn the education you are providing into leads, i.e., “We would be happy to schedule a consultation on reducing the appearance of wrinkles you are experiencing.”
Social Media
In addition to the mass scrubbing you are likely doing with previous regulation changes, you will now be required to take an even finer comb to your social media content and scrub anything that mentions phrases like “wrinkle-reducing injection,” “anti-wrinkle injections,” and “dermal fillers.”
We would ultimately recommend removing anything that mentioned “muscle relaxants” as well since, although not specifically mentioned by the TGA, this phrase is likely going to be considered problematic.
Search Engine Optimization
Since SEO is a fundamental part of all of your marketing efforts, you should consider doing an SEO overhaul. This means finding new keywords and phrases to target, revamping your website’s sitemap to avoid mention of any Schedule 4 drugs, and doing any necessary backend SEO work to remove mention or focus of phrases or topics no longer in compliance.
Advertising
Running social media or web ads will become even more difficult under the new regulations since you can no longer effectively target people with ads for specific treatments. It is still possible to run ads directed toward people who show interest in the development of wrinkles, but advertisement collateral will need to steer away from being results- or product-based and move toward focusing on the practice or provider behind the treatments.
For more context about the recent changes that Australian cosmetic professionals have faced, check out this article. If you have any questions about these changes or how you can get your practice in compliance quickly, feel free to reach out to us at (800) 949-0133 or schedule a one-on-one.