Facebook Advertisement Featuring REJURAN® Injections
As part of a series of posts, and intended for educational purposes only, we highlight some actual posts seen and discuss the potential breaches or even best practice seen in the post. This is not intended to shame but to drive genuine improvement as we all come to grips with the new guidelines and how they build upon the existing guidelines.
Audit Date: 10 July 2025
Platform: Facebook (Sponsored Post)
Treatment: REJURAN® Injections
Clinic: Redacted
File Upload: Yes
Prepared by: Medicom Compliance Auditing
Audit Scope: Social media post and image, reviewed against AHPRA, TGA, AMA, and ACL frameworks.
Key Compliance Breaches Identified:
Component
Description
Breach Type
Guideline Reference
“Enjoy $100 off for new clients”
Inducement (no T&Cs shown)
🔴 Inducements must include full terms and conditions
AHPRA Guidelines for Advertising a Regulated Health Service (Dec 2020), Section 4.2
“Promotes skin healing, hydration, and elasticity” “Smooth fine lines” “Cellular-level repair”
Unsubstantiated therapeutic claims
🔴 Claims must be evidence-based and not misleading
AHPRA Section 4.1; TGA Code 2022 – Evidence for claims
“Take the first step to a healthier, more radiant complexion”
Implies guaranteed/transformational outcome
🟠 Must not create unrealistic expectations of treatment outcomes
AHPRA Guidelines Section 4.4 – Unreasonable Expectation
No disclaimers about risks, individual results, or need for consultation
Missing mandatory warnings.
🟠 Disclaimers must be used for higher-risk procedures
AHPRA + AMA Code of Ethics + Do’s & Don’ts for Non-Surgical Procedures (2025)
Promotion of Rejuran without clarifying ARTG status or regulation
Risk of misleading public about its classification and approved use in Australia.
🔶 Must not imply therapeutic benefit unless evidence-based; classification should be disclosed if unclear.
AHPRA 4.1 + TGA Advertising Guidelines + ARTG Requirements
Important Note From This Case
At first thoughts, our case study flagged Rejuran as a presciption medication. However, when we say that the guidelines are heavily context based, or in this case, classification based, we mean it. For instance, why can you use the brand name Rejuran, but not for instance, Profhilo?
🔍 Important Distinction:
Rejuran is registered on the ARTG as a Class III medical device and is not a Schedule 4 substance. It may be advertised publicly, but only in accordance with TGA medical device advertising laws and AHPRA’s Guidelines for advertising a regulated health service.
⚠ Profhilo, on the other hand, contains hyaluronic acid, which is listed under Schedule 4 of the Poisons Standard. Any public advertising of Schedule 4 prescription medicines is strictly prohibited under the Therapeutic Goods Act 1989.
✅ Always verify product classification and ARTG status before promoting a brand name publicly. Refer to the TGA’s ARTG database and the Poisons Standard when unsure.
| Advertising Element | Compliance Status | Notes |
|---|---|---|
| Reference to “doctor-led clinics” | ✅ Acceptable | Appropriate if accurate; should avoid implying superiority |
| Practitioner roles mentioned (doctors, nurses) | ✅ Acceptable | Acceptable so long as scope of practice is respected |
| General geographical location (Sydney regions) | ✅ Acceptable | Provided patient confidentiality and AHPRA notifications not implied |
| Contact CTA (Call/Visit) | ✅ Acceptable | Acceptable as long as not paired with inducement-only messaging |
Required Amendments
Remove or qualify clinical claims with “may help improve the appearance of…” phrasing.
Add mandatory disclaimer, e.g.:
“Any cosmetic medical procedure carries risk. Individual results vary. A consultation with a qualified health practitioner is required to assess suitability.”
Remove the $100 discount offer unless accompanied by complete, visible terms and conditions.
Replace product-centric visuals with neutral imagery (e.g., consultation scenes or equipment setup).
Final Summary
This Facebook advertisement promoting REJURAN® injections breaches several key regulatory requirements under the AHPRA Guidelines for Advertising a Regulated Health Service, the TGA Advertising Code, and the AMA Code of Ethics. The ad includes:
Unsubstantiated therapeutic benefit claims (e.g. “promotes healing,” “restores structure”),
Although Rejuran is classified as a medical device with the TGA, care should be taken as to the classification of the product and the advertising of injectable product names. Note, other similar products are classed as prescription medicines due to their active ingredients or toxins. It is not always clear cut.
A financial inducement (“$100 off”) offered without visible terms and conditions,
Language that creates an unreasonable expectation of results, and
A lack of mandatory disclaimers regarding risks, variability, and consultation.
While the reference to “doctor-led clinics” and mention of practitioner qualifications is permissible (if accurate), the overall ad poses significant compliance risk and should not be published in its current form.
