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Your ultimate TGA-approved guide to what you can and cannot say about injectables on social media and your website. By NADINE DILONG
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f you’re an injector, and you’ve done your due diligence, you know that in Australia, you are not permitted to advertise Schedule 4 drugs, in other words, you cannot mention any of the actual product names you may be using to inject your patients. You may be following these rules or you may be part of the hundreds of businesses that, every now and then, slip up and post something on social media that could get them in trouble. Seeing the amount of people out there who seem to ignore the TGA guidelines, I think it would be fair to say that the rules aren’t as clear as they should be to many. Questions like, “what exactly is considered ‘advertising’?” and “which terms can I use instead of the brand name?” keep popping up, and so I contacted the TGA directly to get the low-down straight from the source. Let’s start with the basics. All advertising of therapeutic goods in Australia is subject to the requirements of the Therapeutic Goods Act 1989 and the Therapeutic Goods Advertising Code. The Act and code set out the rules for advertising of therapeutic goods to consumers, however they do not apply to advertisements that are solely for health services, such as cosmetic procedures that don’t promote a therapeutic good. In other words, it’s not about the treatment itself, it’s about the products used. In Australia, most cosmetic injectables are regulated as prescriptiononly products and are therefore prohibited from being advertised to the public. This prohibition is based on the principle that the appropriate treatment for an individual patient is a matter for the treating health professional in consultation with their patient, and should not be influenced by consumer advertising, which by its nature is inextricably associated with commercial gain.
What is considered ‘advertising’? According to a TGA spokesperson, “the Act defines ‘advertising’ in relation to therapeutic goods as including ‘any statement, pictorial representation or design that is intended, whether directly or indirectly, to promote the use or supply of the goods’.” This means that anything you post on your website, in e-mail newsletters, or on social media is considered advertising, as you, as an injector and/ 108 | SPA+CLINIC