Enforcement Update – Ads for Botox on social media

Jan 9th '20

Today the Committee of Advertising Practice (CAP) has published new guidance with the Medicines and Healthcare products Regulatory Agency (MHRA) about the advertising of botulinum toxin injections (like Botox) on social media. This includes paid-for ads, non-paid-for marketing posts and influencer marketing.

The Compliance team will take targeted enforcement action after Friday 31st January to ensure a level-playing-field. Where advertisers are unwilling to comply, this may include referral to the MHRA or a relevant professional regulatory body.

In essence, you must take care not to directly or indirectly promote Botox to the public when promoting the treatment services you offer on social media.

Amongst other requirements, you should:

  • Remove direct references to Botox or POMs. This includes names such as “Beautytox” or “Beautox” where the obvious inference is a reference to Botox.
    • Remember – this includes references in images and hashtags like #botox
    • Also – this covers all promotional marketing, like offering “Botox treatment” as a competition prize or in a sale package.
  • Make sure not to substitute direct references to POMs with indirect phrases that can only refer to a POM such as “wrinkle relaxing injections”. This is indirect promotion of a POM, and just as much of a problem.
  • Be aware the ASA considers that a reference to “anti-wrinkle injections” alongside a price that relates to a POM, will be seen as an ad for that POM.

For full details, please see this guidance.

For further advice on advertising botulinum toxin injections in other media, take a look at this recent advice which looks at the issue more broadly.

Source: CAP

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