Making Your Expertise The Marketing Campaign When Injectables Can’t Be

Regulatory guardrails are tightening: the TGA restricts public references to prescription-only injectables, and (on top of that) AHPRA's new higher-risk non-surgical cosmetic advertising guidelines, coming into force on 2 September 2025, will further lift expectations across imagery, influencer use and messaging.

In this environment, the clinics that win won’t be the ones naming products - they’ll be known for judgement, ethics and consultation-first care. Now is the moment to build a personal brand that communicates how you assess, educate and decide, without crossing compliance lines.

Why “now” matters

• The rules just tightened

  TGA’s guidance makes it clear: don’t directly or indirectly promote Schedule 4 medicines to the public (this explicitly includes “anti-wrinkle injections”, “dermal fillers”, brand names, nicknames, hashtags, price lists, testimonials and before/afters). You can promote consultations. (Therapeutic Goods Administration (TGA))

• The next wave lands September 2, 2025

  AHPRA's new guidelines for advertising higher-risk non-surgical procedures add extra constraints across social, influencers, images, and messaging - lifting the bar on disclosure and safety framing. (AHPRA)

• Enforcement is real

  Infringement notices are being issued; recent legal commentary notes fines up to $13,320 per breach (individuals) and $66,600 (companies). That’s per contravention, not per campaign. (Clayton Utz)

When you can’t name or show the Rx, the only thing left to differentiate is your expertise: your framework, ethics, patient selection, complication management, consultation process, and philosophy on “why/when/if”.

That’s also, your personal brand.

Think of personal brand as your go-to and always-on channel when product-based advertising is off-limits.

What to spotlight (and stay compliant)

1. Teach your audience (without naming Rx) Build content hubs on ageing biology, skin integrity, lifestyle factors, prevention, and multi-modal care paths. Teach how you assess faces, not what you inject. Use neutral language and avoid references that lead a consumer to a specific S4 medicine. (Therapeutic Goods Administration (TGA))

2. Safety signals as the hero Publish your consultation flow, red-flag criteria, cooling-off stance, aseptic protocols, emergency readiness and referral network. This aligns with Ahpra’s patient-safety emphasis for higher-risk non-surgical procedures. (AHPRA)

3. Consultation-first offers Swap “Anti-wrinkle from $X” for “Facial Aesthetics Consultation: discuss options to reduce the appearance of wrinkles” - language the TGA itself uses to illustrate compliant service advertising. CTAs should drive to assessment, not a medicine. (Therapeutic Goods Administration (TGA))

4. Case education (not testimonials) Turn outcomes into de-identified clinical reasoning stories: the concern, assessment thinking, risk/benefit lens, adjuncts (skincare, SPF, lifestyle), and aftercare. Avoid patient testimonials and influencer endorsements for higher-risk procedures. (AHPRA)

5. Image strategy that passes the sniff test Retire before/after galleries and “single-image promises”. Use diagrams, sketches, treatment planning screenshots (no Rx names), and standardised photography only where your board allows—and with risk/context copy. (AHPRA)

6. Own your media Build email lists, long-form blogs, webinars and media angles around safety leadership and ethical aesthetics. Owned channels future-proof you as platform policies and regulator guidance evolve. (TGA also reminds advertisers that “health-professional-only” content must not be publicly accessible.) (Therapeutic Goods Administration (TGA))

7. Influence via you, not influencers Ditch paid “I got my injectables at…” content. Do podcasts, panels, op-eds and clinical education where you are the talent. AHPRA's advertising FAQs are explicit about influencer use and testimonials for these procedures. (AHPRA)

Bottom line: with TGA restrictions already in play and Ahpra’s higher-risk advertising guidelines landing on 2 September 2025, the only differentiator you can lawfully scale is your clinical judgement. If a new patient landed on your site today, would they understand how you think, how you decide, and how you keep them safe? If not, that’s the work. Put your name to a clear philosophy, make consultation the hero, and show your standards (education, risk, and ethics) everywhere your brand shows up. Build recognition around the clinician, not the molecule, and you’ll create demand that outlasts rule changes and algorithm swings.