The New TGA Guidelines Are Confusing – But Here’s What You CAN Say In Your Marketing As An Injector

How can you still communicate through your social media with these new guidelines?

With the recent updates to the Therapeutic Goods Administration (TGA) guidelines, the terrain has become even more perplexing. Yet, amidst the confusion, there are apparent pathways for injectors to communicate effectively and compliantly with their audience.

Understanding what can be said within the confines of these regulations is of course paramount for maintaining ethical standards while promoting services and products.

With two industry-leading marketing agencies, The Aesthetic Collective and The Social Aesthetic Co., we break down the intricacies of the new TGA guidelines, outlining what injectors can confidently convey in their marketing, ensuring both transparency and adherence to regulatory standards.

Chloe McGrath, Founder of The Aesthetic Collective

Chloe, what has the reaction to the TGA changes from your clients been like?

The recent changes introduced by the Therapeutic Goods Administration (TGA) have left many clients confused and concerned. The language used in the released documents has resulted in different interpretations among clients, adding to the confusion.

As an organisation, we anticipated these concerns and understand that our clients may have different perspectives on the changes. Our approach has always been to work closely with our clients to find a middle ground that satisfies their needs and concerns.

Some clients have chosen not to make any changes to their websites due to the cost they have already incurred. Others have opted for a more conservative approach, wanting to ensure full compliance with the updated regulations. We respect and understand each client’s unique circumstances and work to develop a customised strategy that aligns with their risk tolerance and business goals.

Our priority is to ensure that our clients feel comfortable with the actions they take on behalf of their business. We continue to provide support and guidance to navigate through the TGA changes, addressing any questions or uncertainties that arise along the way.

What are some compliant content ideas you would suggest to post on social media moving forward?

It is important to shift our focus towards educating patients on how to identify indications of dissatisfaction with their appearance, rather than promoting specific treatments requiring S4 drugs. The TGA aims to prevent patients from self-diagnosing, much like how we discourage them from requesting specific medications from their general practitioners.

By emphasising concerns and indications such as volume loss, facial asymmetries, types of wrinkles, and other factors, we can help patients understand the underlying reasons for their aesthetic dissatisfaction. Educating them on the causes and implications of these issues not only empowers them to make informed decisions but also brings us back to the core of our industry, which is rooted in medicine.

By providing valuable information and promoting a deeper understanding of cosmetic concerns, we can create a more informed patient base that prioritises their overall well-being and seeks professional guidance for their aesthetic needs. This aligns with the principles of responsible and ethical practices in the medical aesthetics field.

An example of a compliant social media caption we would suggest is:

“Well-defined and proportional lips contribute to facial harmony and balance. They can enhance the overall aesthetic appeal of the face by complementing other facial features. Book your consultation to discuss how we can achieve facial harmony and balance. ⁠”

Steph McLean, Founder of Social Aesthetic Co

Steph, in your opinion and according to your clients’ feedback, what has the TGA missed to communicate so far?

I’ve contacted the TGA to clarify certain points, as the guidelines are vague in a few areas and the lack of examples and support is astounding. These are some aspects the TGA need to clarify:

  • Lack of clear communication on who was consulted when establishing the guidelines, leaving them open to interpretation.
  • Absence of a specified timeline for implementing these changes
  • Unclear messaging regarding advertising of a service versus the product
  • Accessing information about the guidelines isn’t straightforward; it would be helpful if the TGA shared steps or actions for business owners and practitioners as well as facilitated the information webinar that was promised in February. 
  • There is no regulation regarding the titles of consultations involving prescription medications. For instance, the TGA does not restrict the use of titles like “anti-ageing consultations”. 
  • The guidelines regarding before and after imagery are excessively vague, leading to confusion. 
  • Who is liable for breaches? The TGA holds the authority to prosecute a business or company. Therefore, if you own a beauty salon and allow an injector to rent a room once per week, it raises questions about the liability of the business owner.

One area that I’m particularly passionate about, which I feel isn’t receiving enough attention, is the long-term impact on businesses in the aesthetics industry. The inability to effectively promote services and build awareness will ultimately harm these businesses in the long run. Content plays a crucial role in online performance, serving as the cornerstone for success in many ways. So for now, we have come up with ways to work around the barriers and effectively communicate with our clients’ potential and existing patients.

Options to remove barriers: 

  • Complimentary consultations
  • Focus on word-of-mouth referrals
  • Always rebook clients for their next appointment
  • Follow up with past clients to check in on their progress and reconnect

Compliant social media caption example 1: Short and concise 

“Looking to smooth wrinkles and restore lost volume? We offer consultations for both.

Schedule your consultation via our link in bio.”

Add disclaimer* 

Pair with; a quote for consultation (if you do charge for consultations, not specific to product usage).

Compliant social media caption example 2: More elaborate 

“Sit down with one of our friendly nurses for a chat about crafting a tailored aesthetic treatment plan just for you!

During your consultation, we’ll review your medical and cosmetic treatment history, skincare routine, lifestyle and aesthetic goals. 

We’ll also take the time to educate you on our services and determine which options align best with your aspirations before assisting in planning the best time to book your treatment, in what order to undertake treatments and taking you through associated risks and aftercare.

Schedule your consultation via our booking link.”

Add disclaimer* 

Pair with: imagery or video of a cosmetic consultation taking place. 

Compliant social media caption example 3: Focus on the treatment areas – SEO focused 

“We offer consultations that can assist you in the treatment of: 

  • Forehead lines
  • Frown lines (between the eyebrows)
  • Crow’s feet (lines around the eyes)
  • Bunny lines (lines on the nose)
  • Lip lines (smoker’s lines)
  • Chin dimpling
  • Neck bands
  • Cheeks
  • Chin 
  • Lips
  • Facial symmetry 

If you want to learn more, schedule your consultation via our link in bio.”

Add a disclaimer*

Pair with: a reel of assessing a patient’s face.

Editor’s note: This article is not intended as legal advice and refers to the TGA guidelines as of 18/3/2024

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