Stephanie McLean Queensland Health’s updated guidance brings big changes to how Schedule 4 medicines can be purchased, stored, and administered. Here’s what every clinic needs to know.
In April 2025, Queensland Health released an updated fact sheet clarifying the legal obligations surrounding the prescribing, purchasing, and administration of Schedule 4 (S4) cosmetic injectables. This follows the initial December 2024 guidance and reflects ongoing efforts to ensure compliance within the cosmetic injectables industry.
Understandably, these updates have sparked concern and in some cases, confusion among Queensland-based cosmetic clinics, particularly those whose current models may not meet the clarified legal requirements.
To help address these concerns, Queensland Health published a dedicated FAQ sheet on April 15, aiming to answer common questions and provide further clarity on how the legislation applies in practice.
Key Takeaways from the April 2025 Update
1. Registered Nurses (RNs) cannot purchase or order S4 Medicines
The fact sheet reiterates that RNs are not authorised to buy or order stock of S4 medicines for cosmetic use, even via third-party websites or wholesalers, regardless of whether payment is made. Ordering is considered “buying” under the legislation.
2. A doctor must have custody and control of medicines onsite
Doctors cannot purchase S4 stock for a clinic where they do not have exclusive custody and control of the medicines. Stock must not be supplied to RNs or other unauthorised staff for clinic storage or use.
3. Onsite doctor presence not mandatory for prescribing, but must be compliant
Doctors or Nurse Practitioners can consult via telehealth and lawfully prescribe S4 medicines, but the overall model still must comply with regulations around dispensing, custody, and control of medicines.
4. Dispensing is restricted to pharmacists and doctors
Only pharmacists and doctors are legally permitted to dispense S4 medicines in Queensland. Medicines must be lawfully prescribed, obtained, and labelled according to the Medicines and Poisons (Medicines) Regulation 2021 and the Commonwealth Poisons Standard.
5. RNs may only hold individually dispensed medicines for clients
While RNs cannot hold general stock of S4 medicines, they may hold individually dispensed medicines prescribed and labelled for a specific client, this must still align with the legislation and professional practice standards.
Implications for Nurse-Led Clinics
These clarifications have significant implications for nurse-led cosmetic clinics in Queensland. Clinics must ensure that their operational models align with the updated guidelines to remain compliant. This may involve restructuring business practices to ensure that only authorised individuals handle S4 medicines and that all prescriptions and administrations are conducted within the legal framework.
Grey areas for clinics doing the right thing
Despite their intent to operate safely and compliantly, many clinics now find themselves in a grey zone due to how the regulations are being interpreted. Key concerns include:
1. Telehealth Prescribing vs Onsite presence
A doctor may prescribe via telehealth, but if they do not have physical oversight or custody of the medication, clinics may fall outside compliance requirements.
2. Stock possession vs Dispensed products
RNs cannot hold general stock of S4 medicines, even if those products were previously prescribed and used safely. Clinics must now ensure every vial is individually dispensed and labelled for a specific client.
3. Doctor ownership without onsite control
Collaborative business models where a doctor is an owner but not physically present may now be non-compliant if they do not have custody and control of stock.
4. Existing stock management
Clinics using shared stockrooms for efficiency and safety now need to completely rethink their systems with little time to transition.
5. Use of third-party ordering platforms
Even initiating an order through a wholesaler or app, regardless of payment, may be interpreted as a breach if done by a non-authorised party.
The Real Cost: Financial & Mental
Financial Costs:
- Restructuring to include full-time medical oversight
- Pausing treatments, losing revenue, and facing potential client dissatisfaction
- Legal advice and compliance audits
- System upgrades for medicine handling and tracking
Mental & Emotional Costs:
- High levels of stress and uncertainty
- Burnout among clinic owners and practitioners
- Concerns around public perception and professional credibility
Navigating the Path to Compliance
Queensland Health has expressed a commitment to working alongside the cosmetic industry to support safe, compliant practice, but for many clinics, particularly those operating nurse-led models, the path forward remains unclear.
As the sector continues to evolve, stronger collaboration between regulators and practitioners is not just beneficial, it’s essential. There is now a critical opportunity to build a framework that upholds public safety while also supporting the businesses and professionals at the core of Australia’s cosmetic medicine industry. To read more about this FAQ sheet, visit health.qld.gov.au.
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