How to use this guide

Start at Section 1 and work down. Use the “Good vs Red‑Flag” bullets and the Master Question List at the end during your consult.

Legal background (read this first)

• Wrinkle‑relaxers (e.g., botulinum toxin) are Schedule 4 (prescription‑only) medicines in Australia; they cannot be advertised to the public.
• Most dermal fillers are regulated as medical devices (not Schedule medicines). They are invasive procedures that still sit under national professional standards and state drugs/poisons law when a prescription medicine (e.g., lignocaine with adrenaline) is used.
• From 2 Sep 2025, new AHPRA guidelines apply across professions for non‑surgical cosmetic procedures (including injectables), and separate AHPRA advertising guidelines apply for higher‑risk non‑surgical cosmetic procedures. Key points include: no asynchronous prescribing (text/email forms), in‑person or video consult every time a cosmetic injectable is prescribed, extra safeguards for under‑18s (mandatory 7‑day cooling‑off, no payment until after the cooling‑off), and stronger ad rules (e.g., real images only, warnings that results vary, no influencer testimonials). ^{1 2 3 4 5 7}

Who regulates what (orientation)

• AHPRA / National Boards (incl. Medical Board): registration, scope of practice, consent, prescribing conduct, non‑surgical cosmetic and advertising guidelines.
• TGA: approval/ARTG listing of medicines & devices; therapeutic goods advertising rules (e.g., no S4 to public; social media rules).
• ACSQHC / RACGP: infection prevention systems and primary‑care clinic standards.
• OAIC: privacy & clinical photography (separate consent for marketing; no storage on personal devices).
• WHO: global patient‑safety benchmarks. ^{1 2 3 6 7 8 9 10 15}

1. Clinical accountability & lawful advertising (most important)

A safe clinic names the clinician assessing you, the prescriber authorising any Schedule‑4 medicines, and the injector treating you. Those roles appear in your consent and record; the prescriber is contactable on the day and afterwards. Advertising must be brand‑neutral, no testimonials, no inducements, no prescription naming (and from 2025, additional controls for higher‑risk non‑surgical cosmetic ads).

Good vs Red‑Flag

• Good: Named prescriber+injector with AHPRA numbers; written policies; generic service descriptions.
• Red‑Flag: “Doctor off‑site”; mystery prescriber; testimonials/giveaways; public content naming or implying prescription products.
• Better questions
• Who will assess, prescribe and inject me (names, credentials, AHPRA numbers)?
• Show me your advertising policy (no S4 references, no testimonials/inducements). ^{1 3 5 7}

2. Emergency readiness & complication management

Time‑critical issues after filler—new severe pain, pallor/mottling, coolness, or any visual symptom—need immediate in‑clinic action and an after‑hours pathway. Best practice: hyaluronidase on‑site, drilled vascular‑event protocol (high‑dose pulsed hyaluronidase, perfusion checks), and urgent ophthalmology/ED for ocular symptoms. Toxin reviews manage asymmetry or heaviness safely.

Good vs Red‑Flag

• Good: Staff can describe doses and steps; direct clinician mobile; documented ocular escalation.
• Red‑Flag: “Wait until morning”; no dissolver on‑site; generic inbox.

Better questions

• Do you stock hyaluronidase and drill a vascular/ocular protocol?
• What is your after‑hours escalation plan for pain/colour change/vision symptoms? ^{2 8 14}

3. Infection prevention you can see (plus audit you can’t)

Expect clean clinical rooms; hand hygiene before gloving; skin antisepsis (chlorhexidine or povidone‑iodine unless contraindicated); single‑use needles/cannulas; sealed sharps containers. Behind the scenes: cleaning schedules, audit logs, incident registers, spill/exposure plans. ⁷

Better questions

• Which antiseptic do you use and why? Is there a written infection‑control policy and room‑turnover log?
• Are all needles/cannulas single‑use and how are sharps disposed of?

4. Real consultation, consent & cooling‑off (it should feel like healthcare)

Before any needle, a prescriber should take history/medications/allergies, examine your face (rest + movement), obtain/store clinical photos with consent, and explain benefits, limits, downtime, risks & alternatives. From 2 Sep 2025: no asynchronous prescribing; in‑person or video consult every time a cosmetic injectable is prescribed; for under‑18s, mandatory 7‑day cooling‑off and no payment until after the cooling‑off. ^{2 3 8 9 10}

Better questions

• What will my consultation cover and what written aftercare will I receive?
• Do you recommend a cooling‑off period for first‑time or higher‑risk treatments? Why?

5. Product governance & traceability (ARTG, storage, reporting)

All injected products must be lawfully supplied in Australia and, where applicable, included in the ARTG. Your record should list product name, batch, expiry; refrigeration/handling must follow instructions. If there’s a device or medicine problem, clinics should help you report it to the TGA and check affected batches fast. ^{11 12 13}

Better questions

• Are all products ARTG‑listed (where relevant) and recorded in my file with batch/expiry?
• How are products stored/monitored, and how will you help me report problems to the regulator?

6. Technique & planning: tailored, conservative, staged

Plans should match your anatomy and goals, not online trends.

• Wrinkle‑relaxers: dose/placement reflect muscle bulk, brow position, and movement.
• Fillers: injector justifies plane (deep support vs superficial refinement) and instrument (needle vs cannula), and often stages higher‑risk or high‑movement areas to improve safety and outcomes. ^{2 8}

Better questions

• How will you adapt dose/placement to my movement and brow shape?
• For filler, which plane and instrument will you use in each area, and will you stage high‑risk areas?

7. Follow‑up, after‑hours support & communication (included vs billed)

Reviews should be scheduled at clinically appropriate intervals and defined in writing as included or billed. Small, clinically appropriate symmetry adjustments should be discussed up front. Provide a direct clinician path after hours with clear response times. If a complication requires hospital care, the responsible prescriber/performer coordinates until handover. ^{2 8}

Better questions

• Is my review included and how are small adjustments handled (fees, if any)? Put it in writing.
• How do I reach a clinician after hours and what response times do you commit to?

8. Privacy, photography & data handling

Clinical photos are health information. Use separate consent for clinical records vs marketing; store images securely; do not store on personal devices; allow patients to withdraw marketing consent later without affecting care. Provide patients the chance to review images before any advertising use. ^{9 10 2}

Better questions

• Do you use separate consent for clinical vs marketing photos, and can I withdraw marketing consent later?
• How and where are my images stored; who can access them?

9. Pricing: transparent, written, no games

You should receive a written quote that lists the service, what’s included, and the review policy. Beware very low per‑unit pricing that hides rushed consults, low dosing, upselling at review, or weak aftercare. Value = qualified assessment, lawful products/devices, safe environment, accessible aftercare. ^{1 6 7}

10. Advertising ethics (no inducements/testimonials; no prescription branding)

Australian rules prohibit advertising prescription‑only medicines to the public and ban testimonials, gifts or time‑limited inducements. From 2025, higher‑risk non‑surgical cosmetic advertising has extra requirements (e.g., real images only, “results vary” warning, tighter controls on influencer content). Keep medicine‑specific detail inside the consult. ^{1 3 5 7 8}

11. Social media & reviews (treat as marketing)

Treat social media as marketing, not proof of skill. Positive signs: education about risks/aftercare and realistic timelines. Red flags: dramatic transformations, giveaways, price‑driven deals, or content that indirectly signals a prescription product. ^{1 5 8}

12. Global alignment

These safeguards mirror the WHO Global Patient Safety Action Plan 2021–2030 focus on clear accountability, rapid escalation for time‑critical adverse events, and partnering with consumers. ¹⁵

Red‑flag checklist (print/screenshot)

• Off‑site or unnamed prescriber; no AHPRA numbers.
• No hyaluronidase on‑site or staff cannot describe vascular/ocular protocols.
• Asynchronous “prescribing” (text or webform scripts) or no consult before toxins.
• Same‑day pressure for first‑time or higher‑risk treatments; for under‑18s, no 7‑day cooling‑off.
• Testimonials, giveaways, influencers; public content naming or implying prescription products.
• Cosmetic wipes instead of medical antisepsis; poor hand hygiene; re‑used trays.
• Missing batch/expiry records; uncertain product origin; expired or poorly stored stock.
• No written review policy; no after‑hours clinician contact. ^{1 2 3 5 7}

Master question list (take this to your consult)

• Governance & people — Who will assess, prescribe and inject me, and how do I reach the prescriber if I’m worried? ²
• Emergency readiness — Do you stock hyaluronidase and drill vascular/ocular protocols? What’s the after‑hours plan for pain, colour change or visual symptoms? ^{2 14}
• Infection control — Which antiseptic do you use; what is single‑use; how are rooms cleaned and audited? ⁷
• Consent & cooling‑off — What will my consult cover, do I get written aftercare, and (if under 18 / first‑time / higher‑risk) what cooling‑off applies? ^{2 3}
• Follow‑up & fees — Is my review included; how are minor symmetry tweaks handled; what response times do you commit to? ²
• Products & traceability — Are products ARTG‑listed (where applicable) with batch/expiry recorded; will you help me report device or medicine problems? ^{11 12}
• Technique & planning — How will you tailor dose/placement; which plane/instrument for each area; and will you stage high‑risk areas? ^{2 8}
• Advertising ethics — Do you avoid testimonials/inducements and any prescription‑product naming in public? ^{1 5 7 8}
• Privacy & photos — Do you use separate consent for clinical vs marketing photos; can I withdraw marketing consent later? ^{9 10}

Appendix — short case studies to test a clinic

A) Night‑time vascular scare after a nose filler

Rising pain + mottling within an hour. Good clinic: answers immediately, brings you in, gives high‑dose hyaluronidase, monitors perfusion, documents ocular escalation, next‑day follow‑up. Weak: “take antihistamines, wait till morning.” ¹⁴

B) Asymmetry after wrinkle‑relaxer

Two weeks later one brow still pulls. Good: invites review, balances dose where appropriate, updates dosing map. Weak: sells a full additional session. ²

C) Photo consent boundary

You consented to clinical photos only. Good: never uses them for marketing without separate consent; removes any post on request and confirms in writing; stores images on a secure device (not personal). Weak: claims blanket consent. ^{9 10 2}

D) Device problem & the ARTG

There’s a safety alert. Good: checks your batch in seconds, contacts affected patients, and helps you report to the TGA. Weak: can’t find batch records. ¹¹

Sources

1. AHPRA — Guidelines for advertising a regulated health service —, viewed 20 November 2025, https://www.ahpra.gov.au/Resources/Advertising-hub/Advertising-guidelines-and-other-guidance/Advertising-guidelines.aspx ↩
2. AHPRA — Guidelines for practitioners who perform non-surgical cosmetic procedures (2025) —, viewed 20 November 2025, https://www.ahpra.gov.au/Resources/Cosmetic-surgery-hub/Cosmetic-procedure-guidelines.aspx ↩
3. AHPRA — Guidelines for practitioners who advertise higher-risk non-surgical cosmetic procedures (2025) —, viewed 20 November 2025, https://www.ahpra.gov.au/Resources/Cosmetic-surgery-hub/Cosmetic-procedure-advertising-guidelines.aspx ↩
4. Medical Board of Australia — Cosmetic medical and surgical procedures guidelines —, viewed 20 November 2025, https://www.medicalboard.gov.au/Codes-Guidelines-Policies/Cosmetic-medical-and-surgical-procedures-guidelines.aspx ↩
5. TGA — Advertising health services & cosmetic injections: FAQs —, viewed 20 November 2025, https://www.tga.gov.au/products/regulations-all-products/advertising/specialised-advertising-issues-and-topics/advertising-health-services-and-cosmetic-injections-frequently-asked-questions-and-answers ↩
6. TGA — Advertising a health service: what you can and cannot say —, viewed 20 November 2025, https://www.tga.gov.au/resources/guidance/advertising-health-service ↩
7. TGA — What can and can’t be advertised to the general public —, viewed 20 November 2025, https://www.tga.gov.au/products/regulations-all-products/advertising/advertising-basics/what-can-and-cannot-be-advertised-general-public ↩
8. TGA — Advertising therapeutic goods on social media: guidance —, viewed 20 November 2025, https://www.tga.gov.au/resources/guidance/advertising-therapeutic-goods-social-media ↩
9. OAIC — Taking photos of patients: privacy guidance —, viewed 20 November 2025, https://www.oaic.gov.au/privacy/privacy-guidance-for-organisations-and-government-agencies/health-service-providers/taking-photos-of-patients ↩
10. OAIC — Guide to health privacy (Australian Privacy Principles) —, viewed 20 November 2025, https://www.oaic.gov.au/privacy/privacy-guidance-for-organisations-and-government-agencies/health-service-providers/guide-to-health-privacy ↩
11. TGA — About the Australian Register of Therapeutic Goods (ARTG) —, viewed 20 November 2025, https://www.tga.gov.au/products/regulations-all-products/about-australian-register-therapeutic-goods-artg ↩
12. WHO — Patient safety: fact sheet —, viewed 20 November 2025, https://www.who.int/teams/integrated-health-services/patient-safety ↩
13. WHO — Global Patient Safety Action Plan 2021–2030 —, viewed 20 November 2025, https://www.who.int/teams/integrated-health-services/patient-safety/policy/global-patient-safety-action-plan ↩
14. RACGP — Infection prevention and control standards for office-based practice —, viewed 20 November 2025, https://www.racgp.org.au/running-a-practice/practice-standards/racgp-infection-prevention-and-control-guidelines ↩