Advertising anti-wrinkle treatments in the UK: what the rules mean for your website, social media and messages

This is a plain-English summary for clinic owners, not legal advice. If you are unsure about a specific ad, the Committee of Advertising Practice (CAP) offers free copy advice, and the guidance pages linked at the end are the authority.

Botox and the other botulinum toxin products are prescription-only medicines (POMs). Under the UK Advertising Code, prescription-only medicines can't be advertised to the general public, and that includes ads for treatments that use them. The Advertising Standards Authority (ASA) enforces this, and since January 2020 it has worked with the medicines regulator, the MHRA, specifically on ads for botulinum toxin on social media.

What counts as advertising

More than most clinics expect. The ASA's guidance covers paid ads, but also your own website, your social media posts, hashtags, influencer posts, price lists, competition prizes and special offers. In its own words, the ban covers references in logos, testimonials, links, hover text, small print and price lists.

Things the ASA has ruled against

• Naming the product. Brand names such as Botox, Vistabel, Dysport, Bocouture and Azzalure in ads aimed at the public, including in hashtags like #botox.
• Made-up names that clearly point to it. Names like "Beautox" or "Beautytox".
• Euphemisms that can only mean one thing. The ASA has said that replacing the name with a phrase that can only refer to the medicine, such as "wrinkle relaxing injections", is still indirect promotion of it.
• A price that gives it away. The ASA considers "anti-wrinkle injections" next to a price tied to a prescription-only medicine to be an ad for that medicine.
• Comparisons and parties. "Better than Botox" claims and "Botox parties" have both been ruled against.

What you can promote

The route the ASA describes is to promote a consultation, not the medicine. Wording along the lines of "a consultation for the treatment of lines and wrinkles" is likely to be acceptable, as long as:

• the consultation is the focus of the ad;
• it is clear that various treatment options will be discussed, and that a particular treatment may or may not follow;
• the prescription-only medicine isn't named in the ad itself, or on your homepage, logo, testimonials or hover text.

On your website, very limited factual information about a prescription-only medicine may be acceptable away from the homepage, kept to the kind of balanced information found in a patient leaflet, and not easy for a casual browser to stumble on.

What this means day to day

1. Check your homepage and price list. These are the places most often caught.
2. Check your hashtags and old posts. The rules apply to social media, and old posts still count.
3. Lead with consultations. Promote the consultation, the practitioner and the care you take, not the product.
4. Brief your team and your tools. Anyone, or anything, that writes your public-facing messages should follow the same rules.

How we handle it

The front desk we build for clinics never names prescription-only medicines in its own wording, and it books consultations rather than treatments. If a patient names a brand themselves, it can acknowledge what they asked, without promoting it, and it steers towards a consultation where the practitioner decides what is suitable. It never diagnoses, and never tells anyone a treatment is right for them.