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How To Advertise PDO Threads and Skin Booster Injections under the New AHPRA Advertising Guidelines

  • Admin
  • Sep 19
  • 6 min read

Advertising PDO threads and skin booster injections in Australia requires strict adherence to the AHPRA higher risk cosmetic procedure guidelines. Clinics must ensure that all marketing materials, including social media, images, and influencer content, comply with these regulations. This guide explains how to advertise PDO threads and skin boosters legally, without using prohibited testimonials or misleading claims.



Understanding AHPRA Guidelines for PDO Threads and Skin Boosters


Why PDO Threads and Skin Boosters Are Considered Higher Risk


PDO threads and skin booster injections are classified as higher risk non-surgical cosmetic procedures. This means that advertising must be carefully controlled to avoid misleading claims, protect public safety, and comply with national law.


Key Compliance Points

  • Do not include testimonials or patient reviews that reference outcomes, experience, or practitioner skill.

  • Ensure all information provided is factual, evidence-based, and non-misleading.

  • Always provide access to information about potential risks or complications, either directly in your advertising or via links to your website.



Testimonials


  1. Are testimonials permitted in higher risk non-surgical cosmetic procedure advertising?


No. Testimonials are not permitted in any advertising of a regulated health service.


  1. What is a testimonial?


A testimonial is a positive recommendation or statement about a clinical aspect of a regulated health service, whether expressed by a patient, a social media influencer or any other person.


In advertising of higher risk cosmetic procedures, any statement or recommendation about the experience of, reason for, or outcome of a higher risk cosmetic procedure, and/or the skills or experience of the registered health practitioner would be considered a reference to a clinical aspect of the higher risk cosmetic procedure and therefore is considered a testimonial. This is because the dominant purpose of a higher risk cosmetic procedure is a revision or change to appearance.


Comments that do not refer to clinical aspects of a regulated health service (e.g. customer service) are not considered testimonials.


  1. How do I comply with the ban on testimonials?


Do not include testimonials in your advertising.


If a social media platform is used to promote a regulated health service, such as a clinic's Facebook page, it is considered advertising and must not include testimonials or purported testimonials.


Specific tips to help make sure your advertising is compliant with the requirements around testimonials include:

  • removing any testimonial that is part of your advertising. This includes removing any testimonials a person may post on your social media page

  • not linking to testimonials on third party sites or review platforms

  • not sharing, liking or re-tweeting any images or comments made by a person about a non-surgical cosmetic procedure provided by you on a third-party website. Sharing or re-tweeting the comment could be considered advertising as it may promote you and your service

  • not interacting with a review, such as liking a patient’s social media post.




Social media and influencers


  1. Can I use social media platforms to advertise higher risk non-surgical cosmetic procedures?


Yes. Social media can be used for advertising higher risk cosmetic procedures as long as you comply with the Guidelines for advertising a regulated health service, and the Guidelines for advertising higher risk non-surgical cosmetic procedures.



  1. What is considered advertising on social media?


Any of the below would be considered advertising:

  • a registered health practitioner, or their business posts content on their own social media accounts

  • a registered health practitioner authorises someone to post content on their behalf (e.g. staff member, a third party or marketing agency) on the registered health practitioner’s, or their business’s social media accounts

  • a registered health practitioner or their business pays for posts on a third-party account, and

  • a registered health practitioner or their business compensates an influencer to post on social media.


For more information about social media see the Ahpra and National Boards’ guidance on social media.


  1. Do I have to include information about risks and potential risks in my social media advertising?


Yes.


It may not be possible to provide full details about risks or potential risks of higher risk non-surgical cosmetic procedures. In this case the advertising should direct the public to the location of the information about risks or potential risks, for example, through a link or directions to the section of the website that contains the information.


  1. Can a health practitioner use influencers to advertise higher risk non-surgical cosmetic procedures?


While the guidelines do not prohibit the use of influencers, there are a number of things to consider before using an influencer to advertise higher risk non-surgical cosmetic procedures.


  1. Can a patient or influencer post about their higher risk non-surgical cosmetic procedure received and tag the clinic they received the procedure from?


No. By tagging the clinic the post will become visible on the clinic’s social media pages and therefore become part of the clinic’s advertising. In advertising of higher risk non-surgical cosmetic procedures, any statement or recommendation about the experience of, reason for, or outcome of the cosmetic procedure, or the skills or experience of the registered health practitioner would be considered a reference to a clinical aspect of the higher risk cosmetic procedure, and therefore is considered a testimonial and is not allowed.




Advice about advertising


  1. Can AHPRA give me advice about my advertising?


No. AHPRA cannot give you advice or an opinion about advertising and cannot check or pre-approve your advertising.


This is because as a statutory regulator our role is to enforce the law and we cannot provide legal advice to advertisers about how to advertise.


The guidelines are intended to support you to comply with your obligations by making expectations clearer and providing examples of unacceptable advertising.


AHPRA and National Boards have also developed resources to help advertisers comply with the advertising requirements. These resources can be found in the Advertising hub.


If you need advice about whether your advertising complies with the National Law, you may wish to seek advice from your professional association, an independent legal adviser or professional indemnity insurer.



Use of images


  1. Can I use ‘before and after’ images in higher risk non-surgical cosmetic procedure advertising?


‘Before and after’ images must:

  • not feature images of people under 18 years of age

  • be used responsibly to provide only realistic information about the outcome of the higher risk cosmetic procedure performed

  • be actual patients who have had a higher risk cosmetic procedure performed by the registered health practitioner advertising

  • not present the ‘after’ image as the most prominent image as this may create unrealistic expectations.


There is also more guidance in the Guidelines for advertising a regulated health service for the requirements for ‘before and after’ images.


Registered health practitioners also need to comply with the Therapeutic Goods Administration (TGA) requirements. See the TGA guidance on advertising a health service for additional information.


  1. Can I use single image stock photos such as a person smiling in advertising higher risk non-surgical cosmetic procedures?


Stock photos will only be suitable in advertising when it is clear that the image is not an outcome of a higher risk non-surgical cosmetic procedure.


Advertisers need to be careful that images used do not give the impression they show the outcome of a higher risk non-surgical cosmetic procedure when this is not the case.


Examples of misleading images include airbrushed, soft-filter or modified images where these modifications remove wrinkles, smooth complexions or otherwise attempt to portray a ‘perfect’ outcome, and the use of models or celebrities where it is not established that the model or celebrity had undertaken the higher risk cosmetic procedure.


To avoid being misleading or deceptive, advertising should be factual and accurate. Advertisers should consider the overall impression of their advertising, including:

  • who the audience is

  • what the advertisement is likely to say or mean to them, and

  • how easy it is for the audience to understand the advertising.




Conclusion


Marketing PDO threads and skin booster injections in Australia requires careful compliance with AHPRA’s higher risk cosmetic procedure guidelines. By avoiding testimonials, using social media responsibly, and presenting images accurately, clinics can advertise safely while maintaining public trust.


For more information, always refer to the AHPRA advertising hub or seek advice from your professional association or legal advisor.



This post is brought to you by MINT Lift ANZ.


MINT Lift provides hands-on training for HCPs looking to expand their skills in MINT PDO thread procedures and skin booster injections.



MINT Lift is exclusively distributed by Athena BioMed (Australia & New Zealand) and SurgeMed (Singapore).


 
 
 

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