This policy must be read with the clinic’s general Governance, Advertising, Privacy, Complaints and Incident Management policies.

1. Purpose

To define how our clinic selects, advertises, recommends and supplies an adult facial moisturiser as a cosmetic product, in a way that:

• Complies with Australian regulation of cosmetics (TGA cosmetic vs therapeutic boundary, AICIS chemical regulation, ACCC product safety and labelling). ^{1 2}
• Complies with Ahpra / National Law advertising obligations whenever the product is promoted in connection with a regulated health service. ^{3 4}

2. Scope

Included

• One or more adult facial moisturisers (creams, lotions, gels) used or sold by the clinic, branded or white-label, for facial skin in adults (18+). ^{1 5}
• All clinical recommendations, written materials, website copy, social media posts and point-of-sale information that describe or promote these products.

Excluded

Any moisturiser that:

• Contains sunscreen SPF > 15 as a primary feature or claim (these are likely therapeutic goods). ¹
• Makes therapeutic claims such as “treats eczema/dermatitis/rosacea”, “repairs the dermis”, “stimulates collagen production”, “treats acne scars” etc. ^{1 6}
• Products intended for children (<18 years) or for treatment of diagnosed skin disease – these require separate clinical and regulatory assessment. ^{1 4}

3. Definitions

Cosmetic product – a substance or preparation intended to be placed in contact with external parts of the human body (including face) mainly to cleanse, perfume, change appearance, protect or keep them in good condition. ^{2 5}

Therapeutic good – a product used for preventing, diagnosing, curing or alleviating disease, or influencing/modifying a physiological process, regulated under the Therapeutic Goods Act 1989 and, where relevant, included in the ARTG. ^{1 8}

Sponsor – the legal entity in Australia responsible for importing, manufacturing or arranging supply of a cosmetic or therapeutic good. ^{1 10}

Regulated health service – a health service provided by an Ahpra-registered practitioner, to which the National Law advertising provisions and Ahpra advertising guidelines apply. ^{3 4}

4. Regulatory Framework (Summary)

4.1 Cosmetic vs therapeutic classification

• TGA guidance states that classification depends mainly on purpose, ingredients and claims. ^{1 4}
• Most basic moisturisers are cosmetics; however moisturisers that:
• Contain sunscreens as a primary feature above SPF 15, or
• Make strong treatment claims for disease or physiological modification are likely to be therapeutic goods and subject to inclusion in the ARTG. ^{1 8}

The products covered by this policy:

• Are intended only to moisturise, soften and support the skin’s barrier.
• Make cosmetic-level claims only (hydration, comfort, smoother appearance).
• Do not make disease-treatment, cure or prevention claims. ^{1 4}

4.2 AICIS – ingredients and introducer obligations

• AICIS regulates the import and manufacture of cosmetic ingredients in Australia. ²
• Any business that imports or manufactures cosmetic products (including moisturisers) must be registered with AICIS and ensure every introduced chemical is authorised (listed, exempted, reported, etc.) under the scheme. ^{2 10}
• The clinic must obtain written confirmation from the sponsor that:
• They are appropriately registered with AICIS;
• All ingredients are introduced in accordance with AICIS rules;
• Safety and record-keeping obligations are met. ^{2 10}

4.3 ACCC / Product Safety – labelling and recalls

• Ingredient labelling must comply with the Consumer Goods (Cosmetics) Information Standard 2020 (mandatory cosmetics ingredient labelling standard). ^{3 7}
• Products must be of acceptable quality, safe for normal use, and not promoted in a false or misleading way under Australian Consumer Law. ³
• Suppliers and retailers have obligations to act on serious safety concerns, including recalls where necessary. ^{3 7}

4.4 Ahpra / National Law – clinic-linked advertising

When moisturisers are promoted in connection with a clinic or doctor, all advertising must comply with:

• Guidelines for advertising a regulated health service; ^{3 4}
• Guidelines for advertising higher-risk non-surgical cosmetic procedures (where content is in the cosmetic procedures space); ^{3 6}
• General consumer law (ACCC). ³
• Advertising must be truthful, not misleading, no guarantees, no testimonials about regulated health services, and must avoid glamorising or targeting young people for cosmetic procedures. ^{3 6}

5. Roles and Responsibilities

Medical Director / Responsible Practitioner

• Approves all clinical and marketing text for the moisturiser.
• Ensures the product remains within the cosmetic classification and complies with Ahpra advertising requirements. ^{1 3 4}

Clinic Manager / Governance Lead

• Maintains supplier agreements, AICIS confirmation and product documentation. ²
• Oversees staff training, stock management, incident reporting and recalls. ^{3 7}

Treating Practitioners and Clinical Staff

• Recommend the moisturiser only within indications in this policy.
• Use cosmetic, not therapeutic, language. ^{1 4 8}
• Document and escalate any suspected adverse reactions. ³

Marketing / Digital Staff

• Use only pre-approved wording and images. ^{3 4 6}
• Avoid testimonials that promote regulated health services or imply medical treatment. ^{3 4}

6. Product Description

6.1 Intended use

Non-prescription, topical facial moisturiser for adults (18+). ^{1 5}

Intended to:

• Hydrate the outer skin layers;
• Soften and smooth the appearance of dry or rough skin;
• Support the skin’s barrier and help it stay comfortable.
• Not intended to diagnose, treat, cure or prevent any disease. ^{1 4}

6.2 Example cosmetic-class ingredient profile

• Vehicle & humectants – water, glycerin, propanediol or similar.
• Emollients / occlusives – triglycerides, squalane, dimethicone, plant oils/esters.
• Barrier-support lipids – ceramides, cholesterol, fatty acids.
• Soothing agents – panthenol, allantoin, oat-derived cosmetic extracts.
• Antioxidants – tocopherol (vitamin E) or similar cosmetic-grade antioxidants.
• Skin-conditioning actives – niacinamide at cosmetic concentrations to support barrier function and the appearance of tone and texture (no therapeutic claims). ^{1 9}
• Preservatives – e.g. phenoxyethanol + ethylhexylglycerin within permitted cosmetic levels.
• Fragrance – either fragrance-free or clearly labelled fragrance/parfum.

Before listing under this policy, the Medical Director / Governance Lead must confirm with the sponsor:

• No ingredient concentration or scheduled substance would re-classify the product as a medicine or breach the Poisons Standard. ^{1 8 10}
• All ingredients are AICIS-compliant and labelled per the mandatory standard. ^{2 3 7}

6.3 Mechanism of action (cosmetic)

• Humectants draw water into the stratum corneum, improving surface hydration.
• Lipids and emollients smooth the skin surface and reduce transepidermal water loss, improving comfort and appearance.
• Antioxidants and barrier-support ingredients help the skin maintain its condition under environmental stress.
• These effects are cosmetic, not therapeutic: no claims are made about treating disease, altering dermal structure or changing physiological processes. ^{1 4 9}

7. Indications, Contraindications, Precautions

7.1 Indications

• Adult patients or clients (18+) seeking:
• Daily facial hydration and improved comfort in dry or tight skin;
• A simple moisturiser to integrate with cosmetic procedures (e.g. lasers, peels, injectables) as supportive skincare, not as treatment. ^{1 4}

7.2 Contraindications

Known allergy or hypersensitivity to any ingredient on the label. ^{3 7}

Clinically obvious skin disease (e.g. active eczema, psoriasis, severe rosacea, infection) where moisturiser alone would be inappropriate – such clients should be directed to their GP or dermatologist. ^{1 4}

7.3 Precautions

History of contact dermatitis or multiple cosmetic allergies – recommend patch test on a small area for 24–48 hours before full-face use. ^{3 7}

Pregnancy / breastfeeding – product remains cosmetic-class only; advise patients to seek medical advice if they have concerns about any specific ingredient. ^{1 4}

8. Procedure – Clinical Recommendation and Use

8.1 Assessment

• Confirm adult age (18+).
• Take a brief history of:
• Skin sensitivities and allergies;
• Current prescription topicals or systemic dermatology medications;
• Recent procedures (lasers, peels, injectables).

If significant disease is suspected, do not position the moisturiser as treatment – recommend medical review. ^{1 4}

8.2 Counselling and language (Ahpra-safe)

Use permitted phrases such as:

• “Helps your skin feel more hydrated and comfortable.”
• “Supports your skin’s barrier and helps keep it in good condition.”

Avoid therapeutic phrases like:

• “Treats eczema/dermatitis/rosacea.”
• “Repairs your dermis or rebuilds collagen.”
• “Fixes pigmentation” or “cures sensitive skin.”

Avoid guarantees and exaggeration:

• No “miracle”, “cure”, “erase wrinkles”, “turns back the clock”, or absolute guarantees of results. ^{3 4 6}

Clarify that:

• The moisturiser is supportive skincare, not a regulated medical treatment, and does not replace appropriate medical care. ^{3 4}

8.3 Application

• Cleanse with a mild, non-medicated cleanser and gently pat dry.
• Apply a pea-to-almond-sized amount to the face (and neck if desired) once or twice daily.
• Massage gently until absorbed, avoiding direct eye contact.

Morning: always follow with a separate broad-spectrum SPF 30+/50+ sunscreen if there is any sun exposure – the moisturiser itself is not a sunscreen product. ^{1 8}

Evening: may be used after non-prescription serums if tolerated. ^{1 4}

8.4 Storage, handling and stock

• Store below 30°C, away from direct sunlight and excessive heat.
• Keep containers closed when not in use; avoid contamination of jars by fingers where possible.
• Use first-in, first-out based on expiry date or “period after opening” symbol. ^{3 7}
• Maintain a stock list including product name, batch number, expiry and supplier. ^{3 10}

8.5 Documentation

Where discussed during a consultation, note in the record:

• “Clinic cosmetic moisturiser recommended – cosmetic-class, non-prescription, for hydration/barrier comfort. No therapeutic claims.”
• For sales, at minimum record batch number and date sold (for recall traceability). ^{3 7}

9. Marketing and Digital Content

When the moisturiser appears on clinic channels (website, social media, brochures, waiting-room screens):

1. Treat it as a cosmetic product, not a treatment.

• Do not present the moisturiser as a medical or surgical procedure, or as a substitute for clinical care. ^{1 3 4 8}

2. Comply with Ahpra advertising and higher-risk cosmetic guidelines where applicable.

• No testimonials or reviews that promote regulated health services or imply a clinical outcome from moisturiser alone. ^{3 4 6}
• Avoid content that glamorises procedures, targets minors or breaches the new cosmetic-procedure advertising restrictions. ^{3 6}

3. Comply with ACCC and TGA-related advertising expectations.

• Claims must be truthful, not misleading and supported by reasonable evidence. ^{1 3}
• Do not blur the line by using therapeutic “medicine-style” language for a cosmetic product. ^{1 4 8}

4. Example compliant descriptors

• “Clinic-curated cosmetic moisturiser for adults seeking daily hydration and barrier comfort.”
• “Helps the skin feel softer, smoother and more comfortable with regular use.”

10. Adverse Events and Product Complaints

Mild irritation (brief tingling, mild erythema, transient dryness):

• Advise temporary cessation or reduced frequency.
• Document in the clinical record or product incident log.

Moderate or severe reactions (persistent erythema, oedema, blistering, suspected allergic contact dermatitis or infection):

• Instruct immediate cessation.
• Arrange review by a clinician or refer to GP/dermatologist.
• Notify the supplier with batch number and details.

Serious or repeated events suggesting a product or batch issue:

• Escalate to Governance Lead.
• Consider withdrawal or recall consistent with ACCC / Product Safety guidance. ^{3 7}
• Document actions taken and patient follow-up.

11. Training

All relevant staff must complete training covering:

• Cosmetic vs therapeutic classification and why claims are critical. ^{1 4 8}
• Basics of AICIS, TGA boundary and ACCC labelling requirements. ^{1 2 3 10}
• Ahpra advertising obligations for regulated health services and cosmetic procedures (including the 2025 non-surgical cosmetic guideline updates). ^{3 4 6}
• This moisturiser policy, permitted phrases, prohibited phrases and incident reporting.

Training completion should be recorded (name, role, date, trainer, content summary).

12. Audit, Review and Version Control

Annual audit of:

• Packaging and ingredients vs label and AICIS/ACCC requirements. ^{2 3 7}
• Website and social media content mentioning the moisturiser (for TGA/Ahpra/ACCC compliance). ^{1 3 4 6}
• Adverse event log and corrective actions. ^{3 7}

Trigger review when:

• Formulation or ingredient concentrations change;
• New AICIS, TGA, ACCC or Ahpra guidance affecting cosmetics or cosmetic advertising is released. ^{1 2 3 4}

Maintain a formal Version Control table with policy number, title, author, approver, effective date and review date.

Sources

1. Therapeutic Goods Administration 2024, Determining if your product is a cosmetic or therapeutic good, Australian Government Department of Health and Aged Care, updated 9 October 2024, https://www.tga.gov.au/resources/guidance/determining-if-your-product-cosmetic-or-therapeutic-good. ↩
2. Australian Industrial Chemicals Introduction Scheme (AICIS) 2024, Personal care, skincare, make-up and other cosmetic products, Australian Government, https://www.industrialchemicals.gov.au/cosmetics-and-soap/personal-care-skincare-make-and-other-cosmetic-products. ↩
3. Australian Competition and Consumer Commission (ACCC) 2023–2024, Cosmetics ingredients labelling mandatory standard / Cosmetic ingredients labelling guide, ACCC, https://www.productsafety.gov.au/business/search-mandatory-standards/cosmetics-ingredients-labelling-mandatory-standard. ↩
4. Australian Health Practitioner Regulation Agency (Ahpra) 2025, Guidelines for advertising a regulated health service, Ahpra, https://www.ahpra.gov.au/Resources/Advertising-hub/Advertising-guidelines-and-other-guidance/Advertising-guidelines.aspx. ↩
5. Australian Industrial Chemicals Introduction Scheme (AICIS) 2024, Cosmetics and soap / Glossary – cosmetics, Australian Government, https://www.industrialchemicals.gov.au/glossary/cosmetics. ↩
6. Ahpra & Medical Board of Australia 2023, Guidelines for registered medical practitioners who perform and advertise cosmetic surgery and procedures, Medical Board of Australia, https://www.medicalboard.gov.au/Codes-Guidelines-Policies/Cosmetic-medical-and-surgical-procedures-guidelines.aspx. ↩
7. Australian Competition and Consumer Commission (ACCC) 2019–2025, Review of the information standard – cosmetics ingredient labelling, ACCC, https://consultation.accc.gov.au/product-safety/review-of-the-standard-on-cosmetics-labelling/. ↩
8. Therapeutic Goods Administration 2022, Is my product a therapeutic good? Decision tree, Australian Government Department of Health and Aged Care, https://www.tga.gov.au/resources/decision-trees/my-product-therapeutic-good. ↩
9. National Health and Medical Research Council (NHMRC) 2021, Factsheet: Cosmetics and therapeutics, NHMRC, https://www.nhmrc.gov.au/sites/default/files/documents/attachments/Factsheet-Cosmetics-and-therapeutics.pdf. ↩
10. International Trade Administration (US) 2023, Australia: Cosmetics regulations, U.S. Department of Commerce, https://www.trade.gov/market-intelligence/australia-cosmetics-regulations. ↩