A Brief Guide to Facial Aesthetics Marketing Regulations

Marketing a facial aesthetic clinic comes with a heightened responsibility to your audience. As with any marketing, it is important not to mislead consumers or exaggerate treatment’s/ product’s capabilities. 

The ASA have devised a guidance document aimed towards the marketing of surgical and non-surgical cosmetic interventions. 

We have summarised the document to offer a brief overview of some things you should and shouldn’t do when marketing your clinic, treatments and products.

Your clinic (and marketers) has a responsibility to the public when advertising treatments and products offered. Care should be taken when using colloquial terms, such as ‘nose job’, so not to downplay the seriousness of a treatment.

Marketing material should also not play on any insecurities, target young audiences (or their guardians), or prominently display prices (as this may encourage people to pick treatments due to price).

The number one rule of marketing facial aesthetic treatments/ products is not to mislead consumers. Marketing materials must not exaggerate the capability or performance of a product or make any unrealistic claims, they must also accurately describe the treatment as colloquial terms could be misleading.

Photo editing is also an important factor. Before and after images must not be edited. However, images are allowed to be digitally retouched so long as it isn’t changing the area of treatment, e.g. a photo of lip fillers could have touched-up imperfections in the photo provided it isn’t editing the lips in any way.

Promotional campaigns surrounding products and treatments in your clinic must be handled with care. The limited time frame for the promotion must be long enough for adequate consideration by consumers.

Therefore ads for the promotion should not be shown too close to the end date, and countdown clocks and claims such as ‘hurry, offer must end Monday’ are banned.

Cooling-off periods, long lead times, and long offer validity do not excuse a rushed purchase as a result of the promotion in the eyes of the ASA.

Promotions should also not pressurise consumers into taking up the offer or encourage people to undergo unnecessary treatments (this includes offering credit for procedures etc.).

Clinics must have evidence that the practitioner is qualified to carry out the marketed procedure(s), they must also have evidence of any claims made.

Using the term ‘qualified’ or ‘highly qualified’ etc. is only allowed if the surgeon/s is/ are on the GMC specialist register. ‘Leading surgeon’ type claims must be provable.

Claims such as ‘Leading clinic’ needs proof to demonstrate that the clinic has qualities to put itself above others. Being able to claim a ‘leading surgeon’ is unlikely to be sufficient as it doesn’t refer to the clinic itself.

Evidence of leading facilities, track record, nursing and other staff would be sufficient to make this claim.

Any treatments/ products stating ‘pain-free’ and ‘without side effects’ type claims also need evidence.

Qualified practitioners may provide information on a condition but not draw attention to a specific POM. The largest POM in the facial aesthetics industry is Botox.

Whilst this is a widely offered treatment, there are many regulations on how and where to use the term Botox (or any variation) due to it being a POM.

Marketing material for your clinic mustn’t include any POM endorsement by either a medical professional or celebrity/ influencer. ‘Botox’, ‘Dysport’, or ‘Botulinum Toxin’ or any other abbreviations cannot be mentioned on social media or on your website homepage (including footers, hover texts, and links). The main website can make limited reference to POM in the appropriate context, as long as it offers a balanced and factual overview.

Promoting a ‘consultation for the treatment of lines and wrinkles’ or ‘anti-ageing treatments’ are allowed, provided other, non-POM options are also displayed.

It must also be made clear that a consultation is needed which may or may not lead to POM treatments depending on the suitability of the client. It is also acceptable to promote ‘treatments for excessive sweating’ provided there is no mention of injections.

Please note this article offers a brief overview of the ASA’s Cosmetic Interventions Advertising Guidance and does not include the full detailed list of regulations in place, please use the link provided to read the full document.

It is recommended that clinics in need of further assistance surrounding marketing regulations should contact the CAP’s Copy Advice team, Clearcast or the RACC as relevant.