Draft non-surgical guidelines

Non surgical guidelines

Use of images including ‘before and after’ images

See also False, misleading or deceptive advertising and Advertising that creates an

unreasonable expectation of beneficial treatment in the broader advertising guidelines.

6.1 Images must not be used in advertising non-surgical cosmetic procedures when the use of the

image is likely to mislead the public because the image gives the impression that it represents

the outcome of a non-surgical procedure where this is not the case. Examples of misleading

images include airbrushed, soft-filter or modified images where these modifications remove

wrinkles, smooth complexions or otherwise attempt to portray a ‘perfect’ outcome, and the use

of models or celebrities where it is not established that the model or celebrity had undertaken

the non-surgical cosmetic procedure.

6.2 Images of people aged under 18 years of age must not be used in advertising of non-surgical

cosmetic procedures.

6.3 All images used in advertising that are intended to show the outcomes of non-surgical cosmetic

procedures must include a prominent warning that the outcomes shown are only relevant for Public consultation:

6.4 ‘Before and after’ images in advertising may create unrealistic expectations and both the

‘before’ and ‘after’ images must be used responsibly to provide only realistic information about

the outcome of the non-surgical cosmetic procedure. The broader advertising guidelines list the

requirements for ‘before and after’ images in advertising. These requirements include that both

the ‘before and after’ images are genuine. In the context of non-surgical cosmetic procedures

this means the images used in advertising must be of actual patients who have had the

procedure being advertised performed by that health practitioner.

6.5 ‘Before and after’ images used in advertising must be presented so that the most prominent or

first image seen is either a combined or composite of both the ‘before’ and ‘after’ images or the

‘before’ image. Advertising where the ‘after’ image is the most prominent image may create

unrealistic expectations.

6.6 ‘Before and after’ images must be as similar as possible in content, lighting, camera angle,

background, framing and exposure, posture, clothing, and makeup. This is to ensure that the

comparisons of ‘before and after’ images are genuine and are not influenced by factors such as

the use of lighting, makeup, facial expression, clothing, or varied angles to improve the ‘after’

image.

6.7 ‘Before and after’ images used in advertising of non-surgical cosmetic procedures must not be

edited or enhanced, for example through the use of filters, retouching, grey-scaling and similar

techniques, as this can be misleading about the results of procedures by enhancing results or

minimising bruising. Registered health practitioners should also consider the timing of ‘after’

images.

When using ‘before and after’ images in advertising non-surgical cosmetic procedures

the ‘after’ image should specify how long after the procedure the image was taken.

6.8 Photographs, videos, or any other imagery used in advertising of non-surgical cosmetic

procedures must be used responsibly, for the purposes of information and/or education about

the non-surgical cosmetic procedures only. Some examples of features that are more likely to

be considered to be focused on entertainment and to trivialise non-surgical cosmetic

procedures include, but are not limited to:

a. imagery that includes music, dancing, singing, or comedic comments

b. editing that is not directed at presenting information (such as a montage of cosmetic

procedures or outcomes, and/or bodies)

c. imagery with a voice-over where the voice-over is not educative or informative.

6.9 The use and descriptions of photographs, videos and images in non-surgical cosmetic

procedures advertising must not:

a. idealise or sexualise non-surgical cosmetic procedures through the use of sexualised

images, such as poses suggestive of sexual positions, parting of legs, hands placed near

genitals or positions that imply sexual readiness, or gratuitous nudity. Other examples of

inappropriately idealised and sexualised images include, but are not limited to,

photographs, videos or images showing sexualised clothing, such as lingerie or sexual

paraphernalia, simulated undressing, such as pulling down underpants or a bra strap, oiled

bodies and similar

b. use icons, such as emojis, to indicate an emotional reaction to an image

c. use lifestyle shots, for example, images taken on a beach, poolside, on a bed, chair, in a

bedroom or hotel roomPublic consultation:

d. capture, or purport to capture, emotional reactions of patients, such as patients giving

‘thumbs up’ or crying with happiness after a non-surgical cosmetic procedure

e. be accompanied by captions or descriptions that idealise non-surgical cosmetic procedures

or minimise the risk of procedures. Examples include, but are not limited to, ‘more natural’,

‘ideal’

, ‘perfect’, ‘instant’, and similar

f. name patients or contain links to a patient’s social media or other digital media account.

6.10 Registered health practitioners must prioritise patients’ interests, dignity, and privacy ahead of

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Correspondence with TGA on advertising guidelines

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TGA Schedule 4 Advertising - IMPORTANT UPDATE FOR ADVERTISING YOUR RESULTS