17 September 2025
The story isn’t over on cosmetic injectables

At least one state wants to see further regulatory action on cosmetic procedures.
AHPRA may have just made moves to reign in the non-surgical cosmetic procedures industry, but Queensland Health Minister Tim Nicholls is pushing for even more reforms – this time, on telehealth.
Just last week, the health practitioner regulator released two new guidelines aimed at health professionals doing cosmetic procedures.
One looked at the expectations and minimum training standards for practitioners doing non-surgical procedures like Botox and fillers, while the other looked at advertising rules.
Introducing the guidelines, AHPRA CEO Justin Untersteiner said the regulator would not hesitate to act if it identifies “practitioners prioritising profits over patient care”.
Mr Nicholls, though, wants to see consistent regulation on the requirements for prescribing, possessing and administration of cosmetic injectables like collagen and botulinum toxins.
He has put the issue on the agenda for Friday’s national health ministers meeting in Perth, which brings together state, territory and federal ministers for health.
“We need national consistency in laws and regulations governing the cosmetic injectables industry to ensure patient safety is front-and-centre,” Mr Nicholls said.
“Effective national standards are needed to ensure patient safety, strengthen clinical governance, and improve clarity of expectations across the industry.”
Queensland has been a particular hotbed for discourse related to cosmetic injectables.
Prior to this year, the state’s Medicines and Poisons Act had largely been interpreted as allowing nurse-run medical cosmetic clinics to hold stock of prescription-only cosmetic injectables so long as a nurse practitioner or doctor made the order and wrote the prescription, even if the prescriber was not necessarily on site.
In April, though, Queensland Health clarified that prescribers can only buy Schedule 4 cosmetic injectable medicines to hold as stock at a clinic if they physically work there and exercise exclusive custody, and that registered nurses were only allowed to possess S4 cosmetic injectable medicines for the purpose of administering it.
This clarification immediately drew pushback from nurse-led cosmetic clinics which had been using GP and nurse practitioner telehealth services in lieu of having a prescriber on site.
Mr Nicholls said he was concerned that inconsistences across jurisdictions had encouraged some operators to structure under the least restrictive models and expand nationally, undercutting legitimate providers.
“I’m concerned that while telehealth provides legitimate support to in-person care in primary health care, within the cosmetic injectables industry, there are rogue operators who have no clinical accountability that could have potentially devastating results for patients,” he said.
“I have put the consideration of the work required to improve governance, oversight and regulatory frameworks for the cosmetic injectables industry on the agenda for Health Ministers to discuss.”
Each state and territory manages its own poisons legislation, which dictates the types of providers who can access, store and prescribe different medicines.
Harmonising regulations across the country would therefore require a coordinated effort from every state and territory.