What a Med Spa Website May Say in the US, UK and Australia

This is a summary of what regulators publish, written for owners. It isn't legal advice. Your medical director, or your lawyer, has the last word on what your site says.

A before-and-after reads as a typical result. Under the FTC's Endorsement Guides, if it isn't typical, the ad has to say clearly what patients can generally expect. Source: 16 CFR 255.2 (ecfr.gov).

You may ask every patient for a review. You may not pay for reviews, offer a discount for them, or hide the bad ones. Source: FTC rule on consumer reviews, 16 CFR Part 465 (ecfr.gov).

States add their own rules. California sets out what a before-and-after must show and say (Business and Professions Code section 651), and Texas has its own medical advertising rules. Prices may be published.

Botulinum toxin is a prescription-only medicine, and those may not be advertised to the public. That covers brand names and phrases like anti-wrinkle injections. The ASA's guidance: no reference to it on a website's homepage, in ads, logos, testimonials or hover text. Promote the consultation instead, such as a consultation for the treatment of lines and wrinkles. A price list may include it if it makes no claims. Don't use before-and-afters for it. Source: ASA, Botulinum toxin products (asa.org.uk).

Most clinics get this wrong. In a UCL sample of 233 London independent clinics, 88% broke the ban. Source: Cosmetics Business, reporting UCL's study (cosmeticsbusiness.com). Fillers aren't prescription-only and can be advertised as fillers, within the CAP Code.

The TGA's advertising code bars promoting prescription-only injectables to the public, including terms such as tox and wrinkle-reducing injections, and their prices. AHPRA's guidelines for cosmetic procedures bar testimonials and require matched before-and-after photos. A watchdog's review of 100 injector websites found almost all of them breaking the rules. Source: B&T (bandt.com.au).

A prescription drug may be advertised to consumers by its name and its price per quantity, with no reference to what it does. Health Canada lists procedure videos and before-and-after pictures among the common Botox breaches. Source: Health Canada (canada.ca).

Name your injectors and their credentials. State the consultation fee. Describe the first visit and what happens if a result isn't right. These are what patients check first, and no rule anywhere stops you saying them.

Rules change, and enforcement varies. The UK's licensing scheme for cosmetic procedures, for one, is confirmed in outline but has no start date yet. Check the regulator's current page before you publish, and have your medical director sign the copy off.