An independent study into cosmetic injectables advertising has found possible widespread non-compliance of TGA guidelines.
A new report from consumer advocacy group Operation Redress has revealed widespread potential breaches of the Therapeutic Goods Administration’s advertising rules when it comes to cosmetic injectables.
The report comes in the wake of the 2024 TGA guideline updates, which explicitly banned terms like ‘dermal filler’ in advertising.
A total of 100 Australian cosmetic clinic websites were analysed for the 34 TGA-prohibited terms.
These terms related to the advertisement of Schedule 4 prescription only medicine, including “cosmetic injectables”, “Botox” and “Brotox”.
Flagged terms were found on 98 of the 100 websites, with “dermal filler” appearing the most, being used 31,874 times.
Violations on the websites were not isolated to singular pages; two thirds of the websites had ten or more pages with non-compliant terms, which Operation Redress called a “consistent disregard for the rules”.
Other violations of TGA guidelines were also found across the majority of the websites, with nearly 60% advertising cosmetic injectables as safe.
“Using these prohibited terms is one thing but pairing them with language which intends to drive insecurities, or with glamorous images, misleading claims, and testimonials creates a culture of putting profits before patients,” Operation Redress co-founder Maddison Johnstone said.
“People should be able to access these treatments free from judgment, but they also should not be misled or manipulated by trusted practitioners through trivialised and glamourised advertising.”
Aside from clinic websites, 40 violations were also found in common advertising tools such as social media and sponsored online content.
Industry arguments were also addressed in the study, with the TGA’s new guidelines receiving heavy criticism by those found to be non-compliant.
Misrepresentation of educational content was a common denominator.
Many of the non-compliant websites argued that their content was for educational purposes despite the use of AI-generated content and misleading language.
“We look at the advertising every day, but even we found it shocking how much potential non-compliance there was when we used our software to examine the metadata, which is what Google uses to deliver search results,” Operation Redress co-founder Michael Fraser said.
“Over 6,000 pages across 98 websites may breach TGA ad rules, creating thousands of pathways which steer patients toward prescription-only drugs through potentially unlawful advertising.”
