· 7 min read · Jason Youngjin Koh
Advertising what you cannot name
The hardest brief in Australian paid media is the one where the product cannot appear in the ad. Not the brand, not the nickname, not the hashtag. Solving that is craft, and the clinics that solve it properly end up ahead.
There is a category of Australian advertising where the single word the customer is searching for cannot appear anywhere in the ad. Not the trade name. Not the shortened version everyone uses. Not the hashtag. Not the price per unit. That is the brief for cosmetic injectables, and it is the most interesting creative constraint we work under.
The shape of the constraint
Most cosmetic injectables contain substances in Schedule 4 of the Poisons Standard, and under the Therapeutic Goods Act 1989 those cannot be advertised to the public. That is the whole rule, and everything else is a consequence of it.
In its FAQs on advertising health services and cosmetic injections, last updated 21 July 2026, the TGA states it no longer expressly permits references to terms such as wrinkle reducing injections or dermal fillers where a reasonable consumer would understand the intention is to promote the use or supply of a prescription-only medicine, and that this includes acronyms, nicknames, abbreviations and hashtags. Stating a price for such a product, total or per unit, is likely to be an advertisement for it.
The TGA declines to publish a list of acceptable substitute terms, which is the part that frustrates everybody and is also the honest position. There is no safe word list, because the test is what a reasonable consumer would understand the intention to be. A term that reads as generic in one ad reads as a substitution in another, and the surrounding creative is part of what a reasonable consumer sees.
What the TGA does say is what works instead: focus advertising on the consultations available rather than the medicines used. That single sentence is the brief. Everything below is how we build to it.
What you advertise instead
Four things are available, and a working campaign usually runs three of them against each other rather than picking one.
The consultation
The TGA's own direction, and the safest ground available. The thing being advertised is an appointment with a practitioner to discuss options, which is a health service rather than a therapeutic good. It is also the least differentiated of the four, because every competitor can say it, so it needs the practitioner or the clinic to carry the distinctiveness.
The concern, stated neutrally
The area of the face or the aesthetic goal, described without naming a product and without asserting anything about the person reading. This is where two regulators collide. Australian law pushes you away from the product and toward the concern. Meta's Privacy Violations and Personal Attributes policy pushes you away from asserting a concern about the reader. The intersection is narrower than either rule alone, and it is real work to write inside it.
The practitioner
A named person with visible credentials is the strongest asset most clinics own and the one they under use. It is also the asset that carries an obligation attached: AHPRA's guidelines for higher risk non-surgical cosmetic procedures require advertising that names an individual who performs them to include their registration number. Build the creative so that requirement is designed in rather than bolted on.
The outcome category
Broad, non promissory language about the kind of result being sought rather than the result being delivered. This is the narrowest of the four and needs the most care, because AHPRA prohibits creating an unreasonable expectation of beneficial treatment, and the cosmetic guidelines specifically rule out phrases in the register of happier you or best version of yourself.
| What the clinic wants to run | Why it fails | What we run |
|---|---|---|
| The product name, or its abbreviation | An advertisement for a prescription only medicine | A named practitioner and a consultation, in a named suburb |
| A hashtag version of the product name | The TGA states this includes acronyms, nicknames, abbreviations and hashtags | Hashtags on the clinic, the location and the practitioner |
| $X per unit, this month only | Stating a price is likely an advertisement for the product | A consultation offer with its terms stated in the ad |
| A booking page listing injectable treatments by name | A public booking system allowing self selection of prescription only treatments is likely an unlawful advertisement | A booking page offering a consultation, with treatment discussed in the room |
| Tired of your frown lines? | Meta reads a second person assertion about the reader's appearance | Consultations for facial aesthetics with Dr Name, Chatswood |
One more consequence clinics regularly miss: the TGA is clear that all social posts must comply, historical as well as new. The audit is not only of what you are about to run. It is of the two hundred posts already sitting on the account, and on Meta the ad's destination is reviewed alongside the ad, so a compliant ad pointing at a non compliant page fails as one unit.
How a consultation led funnel behaves
This is the part that changes our numbers rather than yours, and it is worth being direct about it because it looks like underperformance if nobody explains it in advance.
You cannot use price as the hook, which removes the highest performing shortcut in the category. You cannot use the product name, which removes the exact phrase people are actually searching. And the ask is a conversation rather than a purchase, which is a larger commitment than a price led offer even though it costs the person nothing.
So the volume comes down and the cost per enquiry goes up, against a competitor who is breaking the rules and against your own history if you used to break them. That is the trade, stated honestly at the start of the engagement rather than discovered in month two. What moves in the other direction is everything after the enquiry, and that is where the campaign is actually judged.
$60,000
Maximum financial penalty per advertising offence for an individual under the National Law, and $120,000 for a body corporate. Source: AHPRA, Advertising and the law, accessed September 2026. The competitor running the cheaper ad is carrying this, not saving money.
Why the constraint produces better enquiries
Not a consolation. A mechanism, and a fairly blunt one.
An ad that leads with a per unit price selects for people comparing per unit prices, and the clinic that wins that comparison is the cheapest one in the suburb. You are structurally excluded from competing on that axis, so the enquiry that reaches you has responded to a practitioner, a clinic and a consultation instead. That is a different person arriving with a different question, and the conversation starts from suitability rather than from a number.
It also means the enquiry cannot have been made on a misunderstanding of what is on offer, because nothing specific was offered. Nobody arrives having already decided which product they want at which price and simply looking for someone to administer it. Whether that is commercially better depends on your own numbers, and you have those. What we can say is that the two campaigns are not comparable on cost per enquiry, and comparing them on that basis is how a compliant campaign gets switched off in favour of one that should never have run.
What this looks like as a build
- Audit everything public first: website, booking system, Google Business Profile, and every historical social post, not just the new creative.
- Take prescription only treatment names and prices off any page a member of the public can reach, including the booking flow.
- Build the creative around a named practitioner with a registration number where the guidelines require one, so compliance is structural rather than a caption edit.
- Write concern led copy that describes a service rather than asserting an attribute of the reader, because it has to clear the Australian rules and Meta's policies at once.
- Agree in writing, before launch, that this campaign is judged on enquiry to consultation attended and not on cost per enquiry.
- Name one person who signs off advertising before it goes live, on your side, not ours.
The clinics that do this properly stop competing with the ones that have not, which is the outcome nobody expects at the start. A compliant campaign cannot be beaten on price by an ad that is not allowed to mention price either, once the regulator gets there.
The injectable restriction is one rule among several: the full set of rules, with every one attributed