This page explains the rules as published by the regulators. It isn't legal advice. Check your wording with your professional association, an independent legal adviser or your professional indemnity insurer.
What does the TGA say?
The Therapeutic Goods Administration (TGA) regulates advertising of therapeutic goods, including medicines. Its guidance for clinics says:
- Most cosmetic injection treatments involve prescription-only substances. These are in Schedule 4 of the Poisons Standard and, under the Therapeutic Goods Act 1989, can't be advertised to the public.
- No references, even indirect ones. Advertisers can't refer, directly or indirectly, to prescription-only substances or to the trade names of prescription-only goods. That includes acronyms, nicknames, abbreviations and hashtags.
- Generic terms are no longer a safe workaround. Some generic terms that were once accepted are no longer expressly permitted where a reasonable consumer would read them as promoting a prescription-only medicine.
- Promote the consultation. The TGA says clinics should focus their advertising on the types of consultations available.
Sources: TGA guidance on advertising health services that involve therapeutic goods and the TGA's frequently asked questions on advertising health services.
What do AHPRA's guidelines cover?
AHPRA and the National Boards publish the Guidelines for advertising higher risk non-surgical cosmetic procedures, in effect from 2 September 2025. According to AHPRA:
- The guidelines set out the types of advertising of higher risk cosmetic procedures, performed by registered health practitioners, that will breach section 133 of the National Law.
- They apply to anyone advertising these procedures: registered health practitioners, individuals who aren't registered, and businesses, partnerships and corporate entities.
- Testimonials aren't permitted in any advertising of a regulated health service.
- AHPRA can't give advice on, check or pre-approve your advertising.
Source: AHPRA resources for advertising higher risk non-surgical cosmetic procedures.
What does consult-first booking look like?
Consult-first means you promote and book the consultation, not a product. In practice:
- Talk about the concern, not the product. For example, "We offer consultations for skin concerns" or "Our practitioner can talk you through your options at a consultation."
- Book the consultation first. The practitioner decides whether any treatment is suitable, at the consultation.
- Leave out price promotions and before-and-after images for these treatments.
How should your clinic handle phone enquiries?
Many enquiries start with a call, and callers often use product names themselves. A consult-first phone approach keeps your side of the conversation generic:
- "How much is it?" "Pricing depends on what your practitioner recommends. The first step is a consultation. Would you like me to book one?"
- "Do you do [a product name]?" "Our practitioners offer consultations for that concern. They'll talk through your options and whether anything is suitable for you."
- "Can I just book the treatment?" "New clients start with a consultation with one of our practitioners. I can book that for you now."
- A reaction or aftercare question. "I'll put you through to the clinic team now," or take a message for them to call back.
- An emergency. Tell the caller to ring 000.
The rules we've quoted cover advertising. The pages we read don't say how they apply to a private one-to-one phone call, so check your call scripts with an adviser.
How does CallPad handle these calls?
CallPad is an AI receptionist for Australian cosmetic and skin clinics. On a call, it:
- uses your approved, consult-led wording
- books consultations in real time with a named practitioner in Cliniko, Shortcuts, Simple Salon, Phorest or Google Calendar
- gives no clinical advice
- sends reaction, complication and aftercare calls to your team: CallPad can transfer the call to a team member or take a message
- can direct anyone describing an emergency to ring 000
This is configuration your clinic controls, not a guarantee of compliance. CallPad complies with the Australian Privacy Act. Our security overview explains how we protect client data. See our page on CallPad for Australian cosmetic clinics.
Frequently asked questions
Can Australian clinics advertise prescription-only cosmetic products?
No. Most cosmetic injection treatments involve prescription-only substances that can't be advertised to the public, according to the TGA.
When did AHPRA's guidelines for higher risk non-surgical cosmetic procedures start?
They've been in effect since 2 September 2025.
Do the guidelines apply to businesses, not just practitioners?
Yes. AHPRA says they apply to anyone advertising these procedures, including registered practitioners, unregistered individuals and businesses.
Do the rules cover phone calls?
They cover advertising. The pages we read don't say how they apply to a private phone call, so check your call scripts with an adviser.
Will CallPad give clinical advice?
No. Clinical, reaction and aftercare calls go to your team.
Does CallPad comply with Australian privacy law?
CallPad complies with the Australian Privacy Act.
Talk to us
Book a demo for your clinic, or hear CallPad take a call.
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