Media Release
A report released by consumer advocacy group Operation Redress has revealed that 98% of cosmetic injectables clinics are breaching strict advertising rules governed by the Therapeutic Goods Administration (TGA).
This comes one year after the TGA updated its guidance on advertising cosmetic injectables, explicitly banning terms like ‘dermal filler’.
The report analysed 100 websites of Australian clinics for 34 terms prohibited by the TGA when advertising Schedule 4 prescription-only medicine, including ‘cosmetic injectables’, ‘dermal filler’, ‘Botox’, and ‘Brotox’. Flagged terms were found on 98 out of the 100 websites.
‘Dermal filler’ was used 31,874 times, ‘cosmetic inject*’ was used 16,671 times, ‘Botox’ was used 2,983 times, and slang terms for Botox (‘Brotox’, ‘Haytox’, ‘Scrotox’, and ‘Traptox’) were used 435 times.
The prevalence of potential breaches within websites was also evaluated, finding 67% of websites had ten or more pages with at least one non-compliant term. This indicated the use of prohibited terms was not isolated and instead highlighted a consistent disregard for the rules.
Cosmetic injectables were also advertised as safe in 59% of websites analysed, which the TGA also prohibits.
Researcher Maddison Johnstone said websites often downplay the risks and glamourise medicines, which she argues is not patient-centric and instead causes unrealistic expectations.
“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,” 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.”
Researcher Michael Fraser said while the TGA does important work, the data showed room for improvement in enforcing advertising rules.
“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,” 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.“
The report also identified 40 other advertising platforms injectors use to market their services using non-compliant language, including bus advertisements and social media.
The report comes as the Australian Health Practitioner Regulation Agency (AHPRA) released new guidelines for practitioners who advertise cosmetic injectables. These guidelines come into effect in September
Ends
Background - Report
- Each website represents a separate business, covering 530 clinics across all Australian states and territories.
- Information was collected from publicly available websites and social media accounts in March and April of 2025.
- Using proprietary software and Google’s search engine, 100 websites were selected for review from each of the locations listed: Adelaide, Brisbane, Canberra, Darwin, Hobart, Melbourne, Perth and Sydney.
- The search term used to select 100 websites was “cosmetic injectables” (not in quotes) and the sample from each location was selected from within a five kilometre radius of a central point.
- Only the TGA can definitively determine that a breach occurred. In the Report we often refer to breaches as ‘potential breaches’, ‘potential non-compliance’, or ‘mentions’ of prohibited terms.
- The report outlines tens of thousands of instances where non-compliant terms have been used across a 100 website sample. We do not suggest that where multiple non-compliant terms have been used on the one page, that this represents multiple advertisements. For example, if five non-compliant terms were used in one blog post, we do not suggest that this represents five advertisements. We only suggest that there were five instances of a non-compliant term being used on the one page.
- Report Contents (at a glance): snapshot of statistics pages 4-5, analysis pages 8-9, graphs pages 10-11, industry arguments page 15.
General
- Cosmetic injectable medicines like botulinum toxin and dermal filler are Schedule 4 on the ARTG, and cannot be advertised.
- The TGA does not provide an extensive list of terms which are prohibited in advertising.
- During the compilation of this report, the TGA wrote to cosmetic injectables industry groups regarding the formation of the Targeted Compliance Unit (TCU), which will enforce advertising rules.
- AHPRA regulates healthcare providers, while the TGA regulates medicines.
Maddison Johnstone 0434 003 822
Michael Fraser 0458 369 975
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*Not medical, legal or financial advice
Published: 10 June 2025