Posts about injectables, fillers and laser treatments sit at the point where beauty content meets medicine. This article explains what UK advertising guidance from the Advertising Standards Authority (ASA) and the Committee of Advertising Practice (CAP) says about promoting cosmetic treatments, including on social media. It describes the UK system only; other countries have different rules, and platforms add their own.
Why do cosmetic treatments get special treatment in advertising rules?
Two separate concerns apply. The first is that some treatments involve prescription-only medicines (POMs), which in the UK cannot be advertised to the public. The second is that cosmetic procedures of any kind are a decision about a person’s body, so the rules ask advertisers to act responsibly and avoid misleading claims.
According to the ASA’s advice page on cosmetic interventions, the guidance covers surgical and non-surgical interventions, from breast augmentation to injectables such as Botox and fillers, chemical peels and non-ablative laser treatments. The page lists topics including trivialising treatments, targeting of ads, exaggerated or unrealistic claims, before-and-after images and the way qualifications are described.
CAP’s Bitesize page adds a wider list of non-surgical examples: fillers, skin-rejuvenating injections, laser or light treatments, microneedling, micropigmentation and teeth whitening.
Can a clinic or creator name Botox in a post?
Generally no. CAP’s Bitesize page says that Botox, Vistabel and Dysport are POMs that cannot be advertised to the public, citing CAP rule 12.12 and MHRA regulations. The ASA’s enforcement notice, first published on 9 January 2020 with the Medicines and Healthcare products Regulatory Agency (MHRA), says advertisers must take care not to directly or indirectly promote Botox to the public when promoting treatment services on social media.
The ASA’s published examples of what to avoid include:
- brand-style names such as “Beautytox” or “Beautox”, where Botox is the obvious inference;
- hashtags such as #botox;
- references within images, not only in captions;
- offering “Botox treatment” as a competition prize or as part of a sale package;
- indirect substitutes, since a phrase like “wrinkle relaxing injections” is still treated as indirect promotion of a POM.
The enforcement notice states that the guidance covers paid-for ads, non-paid-for marketing posts and influencer marketing alike. It also says advertisers who will not comply may be referred to the MHRA or a relevant professional regulatory body.
What can be promoted instead?
CAP’s Bitesize page sets out the permitted side of the line. A clinic can promote consultations for wrinkles on any channel, including social media, leaflets and its website. It can promote the clinic itself, non-POM services such as fillers, and its qualifications and experience.
The page also gives website-specific detail. Botox may appear only as a potential outcome of a consultation or in a price list, the content must be purely informational, and it must not appear on a homepage, in hover text, in small print or in testimonials. It is not permitted in paid advertising or on a business’s own social media. Before-and-after photos of Botox are also off limits, because they are visual claims and breach the rules without any wording.
Testimonials are allowed if they do not directly or indirectly reference Botox or other POMs, can be substantiated, are genuine and have the person’s permission.
What does the rule on price say?
Pricing is a common trap. The ASA’s enforcement notice says that “anti-wrinkle injections” shown alongside a price tied to a POM is treated as an ad for that POM. CAP’s Bitesize page says a Botox price may appear in a price list only after users click through consultation pages, not directly from the homepage.
Price lists should clearly relate to the advertised treatments and include all non-optional charges, such as booking fees or deposits. Where the cost depends on a consultation, the page says the ad should say so and explain how the price is calculated.
Are there rules on who can see these ads?
Yes. CAP and BCAP introduced rules on 25 November 2021 prohibiting cosmetic interventions advertising from being directed at under-18s, according to the ASA’s 12-month review published on 12 December 2023. The targeting restrictions took effect on 25 May 2022 after a six-month implementation period. CAP Code rule 12.25 covers non-broadcast media, including online, and BCAP Code rule 32.2.9 covers broadcast.
| Medium | Rule | What it requires |
|---|---|---|
| Non-broadcast (including social media) | CAP Code 12.25 | No ads in media directed at under-18s, or where under-18s make up over 25% of the audience |
| Broadcast | BCAP Code 32.2.9 | No ads during or next to programmes made for, or likely to appeal particularly to, under-18s |
The 12-month review found no factors that would prompt a change to the rules or their wording, and its proactive monitoring found no clear breaches. It did say that in some cases advertisers could make better use of targeting tools to reach adult audiences. CAP’s Bitesize page advises checking an influencer’s following before a collaboration.
An illustrative example, which is the article’s own arithmetic rather than anything the ASA publishes: if an influencer’s audience data showed 1,000 followers, the 25% threshold would be reached at 250 under-18s. A share above that, such as 300 of 1,000 (30%), would exceed it. Real audience data is rarely so tidy, and the rule is framed around the audience of the medium, so the figures show the principle only.
How should the “responsible” test apply to a creator’s post?
The ASA’s guidance on social responsibility, as summarised on the Bitesize page, asks advertisers not to trivialise the decision to have a treatment, use time pressure such as countdowns, or play on insecurities. It also says prize promotions should include a strict consultation first, and CAP recommends contacting its Copy Advice service beforehand.
For creators, this is the article’s reading of the guidance: a “last chance, book today” countdown or a giveaway of a treatment is higher risk than a calm description of a clinic and its consultation process. The sources do not rank individual formats, so this should be read as an interpretation of the principle.
Do filters and edited images count here?
They do. CAP’s Bitesize page says before-and-after photos for non-surgical treatments need signed, dated proof that they are genuine and unaltered. Advertisers should not use retouching, filters or concealer on treatment areas, and should keep records of pre- and post-production changes. Disclaimers rarely fix a misleading impression.
This matches the wider UK approach to edited beauty imagery, covered in more detail in our explainer on beauty filters in cosmetics ads. The Bitesize page also says that around 70% of the ASA’s work in this area concerns misleading claims, so exaggeration is the most frequent issue. It adds that advertisers should be transparent about practitioners’ qualifications, not imply a medical status they lack, and keep evidence for any qualifications they claim.
Who is responsible when an influencer posts?
The Bitesize page states that celebrity or influencer promotion of Botox still counts as advertising, and that endorsing POMs is not allowed. It also says the business remains responsible for influencer ads, and suggests including a clause in agreements prohibiting misleading filters or enhancements.
Labelling is a separate requirement. A paid or gifted treatment promoted by a creator still has to be identifiable as marketing, and the rules on that are summarised in our guide to influencer disclosure rules in the UK, US and EU. The way commercial arrangements are structured is covered in gifting, affiliate and paid deals, and what happens after a complaint in how the ASA handles complaints about influencer ads.
A quick reference for reading a treatment post
Using only the published guidance above, these are the questions a reader or compliance team could ask of a post. This list is the article’s summary, not an official checklist:
- Does it name Botox, use a lookalike name or hashtag, or show it in an image?
- Is a price shown beside an “anti-wrinkle injection” phrase?
- Is the audience likely to include more than 25% under-18s?
- Does it use time pressure, a prize or language that plays on insecurity?
- Are before-and-after images filtered, retouched or lacking dated proof?
- Are the practitioner’s qualifications described accurately?
Reading cosmetic treatment content with the rules in mind
The published guidance draws a consistent line. Clinics and creators may talk about consultations, the clinic and non-POM services, but not promote prescription-only injectables to the public, whether directly, indirectly or through a price. Everything is expected to be responsibly targeted and free of misleading edits. As of the sources consulted, the ASA’s most recent review of the under-18 rules left them unchanged. Readers seeing a post that appears to cross these lines can look at how the complaints process works, remembering that outcomes depend on the facts of each ad.
This article is general information based on published ASA and CAP guidance, not legal, medical or regulatory advice. Rules and platform policies change, and it describes the UK system only.
Sources: Advertising Standards Authority (cosmetic interventions); Advertising Standards Authority (Enforcement Update – Ads for Botox on social media); Advertising Standards Authority (Training videos: rules for advertising Botox); Advertising Standards Authority (Cosmetic interventions targeting rules - 12 month review)
