Botox and non-surgical cosmetic interventions

CAP Bitesize videos

This short video series covers the advertising rules for non-surgical cosmetic interventions with a separate video for the rules that apply to Botox (and other prescription anti-wrinkle treatments). You can watch the whole thing in less than 20 minutes.

Introduction

On 25 May 2022 the rules for advertising non-surgical cosmetic interventions changed. Find out what this means for your marketing in this video.

Social responsibility

Learn how to keep your ads for non-surgical cosmetic interventions responsible.

Production techniques

Keep your before-and-after photos in check. Find out more about how the advertising rules apply to the production techniques used to promote your non-surgical cosmetic interventions.

Misleadingness

Get top tips on how to avoid misleading advertising claims when promoting your non-surgical cosmetic interventions.

Disclaimer: In April 2025, CAP and BCAP introduced amendments to the rules to reflect new UK consumer law – the Unfair Commercial Practices (UCP) provisions in the Digital Markets, Competition and Consumers Act 2024. The UCP provisions update and replace the Consumer Protection from Unfair Trading Regulations 2008 (the CPRs). However, the key principles remain largely the same, with some slight changes to wording and definitions and the addition of new prohibited commercial practices. The changes are subtle and, in most cases, do not result in the ASA taking a significantly different approach than it did previously, although certain positions have been strengthened. These videos reflect the ASA approach pre-UCPs and there are some areas where formal ASA precedent still needs to be established, but the content remains broadly relevant.

Botox

This video covers the advertising rules for Botox and other botulinum toxin injectables.

The Dos and Don'ts of Advertising Botox

Don't advertise Botox to members of the public.

Botox and its other brand names, such as Vistabel and Dysport, are a prescription-only medicine (POM). This means that it cannot be advertised to the public, as set out in the advertising rules by CAP (rule 12.12) and regulations from the MHRA.

There are only very limited circumstances in which you can mention Botox or other POMs on your website. You cannot do so on social media or in any other advertising space.

	Dos		Don'ts
	Do watch the CAP Bitesize videos They’ll help you understand what you can and can’t say in ads for your services.		Don’t mention Botox or use indirect references to it in your ads This includes phrases like “wrinkle-relaxing treatments”, or even things like “#brotox” or “#beautox”. This applies to posts on social media, leaflets and posters, and almost all website content.
	Do promote a consultation for wrinkles You can advertise consultations for wrinkles – including on social media, in leaflets and on your website.		Don’t share before-and-after photos of Botox These are considered visual claims and break the rules – even if you don’t include any wording.
	Do promote your business You can promote: your clinic and other non-POM services, such as dermal fillers your experience and qualifications.		Don’t use celebrities or influencers Having celebrities or influencers promote Botox still counts as advertising. And they’re not allowed to endorse any medicines.
	Do share testimonials You can feature testimonials – as long as they don’t directly or indirectly reference Botox (or other POMs), or make claims you can’t prove. You must also be able to show that they’re genuine and that you have permission to use them.		Don’t advertise promotional offers on Botox Promotional marketing is still advertising – and it’s not allowed for Botox or other POMs.
	Do ask for help if you need it If you have a question or you’re unsure about your ad or website, get in touch. You can contact our Copy Advice service and they’ll be happy to help.		Don’t assume that others know the rules Just because you see others talking about Botox online or in ads, don’t assume they’re following the rules.

You can mention Botox on your website in two specific circumstances.

1. As a potential outcome of the consultation
2. In your price list

But the reference must be:

• Purely informational with no promotional content – like the kind of thing you'd read in a patient information leaflet.
• Not on your homepage.

You are not permitted to mention Botox in any paid advertising or on your own social media channels.

Related content

Articles that cover the topics above in more detail:

Botox FAQs – Answers to common questions about how Botox can (and can’t) be referenced in ads, including on social media and websites.

Botox AdviceOnline – An outline of the strict rules for advertising botulinum toxin products like Botox, with practical dos and don’ts.

Cosmetic Interventions Advertising Guidance – Detailed guidance on how the advertising rules apply to all cosmetic interventions, including both surgical and non-surgical procedures.

Non-Surgical Procedures AdviceOnline – Key rules for promoting non-surgical cosmetic treatments such as fillers, microneedling and skin rejuvenation.

Prescription-Only Medicines AdviceOnline – Explanation of the rules that apply specifically to prescription-only medicines (POMs) and why they can’t be advertised to the public.

Beauty and Cosmetics: General AdviceOnline – General guidance on beauty and cosmetic ads — including claims, imagery, and targeting considerations.

Social Responsibility in Cosmetic Ads AdviceOnline – How to ensure ads for cosmetic interventions are socially responsible and don’t exploit insecurities or pressure people into treatment.

Transcripts

• 

  Introduction

  We’ve created this CAP Bitesize series to make beauticians, dentists, and other practitioners offering non-surgical cosmetic interventions, aware that the rules for these kinds of ads have changed.

  What are non-surgical cosmetic interventions?

  So, what do we mean when we’re talking about non-surgical cosmetic interventions? This refers to any cosmetic procedure, intervention or treatment where the main purpose is to change an aspect of a customer’s appearance.

  Things like facial fillers and skin-rejuvenating injection treatments, laser or light treatments, microneedling, micropigmentation and teeth-whitening treatments are just a few examples.

  What’s changed?

  So, what’s changed?

  In a nutshell, as of 25 May 2022, all ads for non-surgical cosmetic interventions must not be targeted at under-18s. For non-broadcast media — that’s online, social media, marketing emails, print ads, posters and leaflets — these ads can’t appear in media where under-18s make up 25% or more of the audience.

  In practice

  What does that mean in practice?

  It means you need to think carefully about where you advertise and post promotional content for these kinds of treatments.

  For example, say you were advertising your services for fillers. You wouldn’t be able to advertise on websites (other than your own) where 25% or more of the audience are under 18. If you’re advertising on social media, you’ll need to be careful how you target those ads — making sure you take all reasonable steps to avoid reaching under-18s.

  Social media and influencers

  This rule also includes working with influencers.

  If you want to collaborate with a content creator or someone on social media, you need to check whether their following includes under-18s — and whether they make up 25% or more of their audience.

  If that’s the case, any posts advertising cosmetic interventions would break the advertising rules.

  Stay tuned — next, we’ll cover some of the other key rules that apply to ads for non-surgical cosmetic interventions.

• 

  Social responsibility

  Welcome back to the second video in this series on advertising non-surgical cosmetic interventions.

  The advertising rules are clear: ads must be responsible. In this video, we're going to explore what that means when it comes to your ads for non-surgical cosmetic treatments and procedures.

  There are a few key principles to keep in mind when you're putting together a post or ad for your services.

  1. Don’t trivialise the decision to have a procedure or treatment

  Even non-surgical cosmetic interventions aren’t entirely without risk. For example, fillers may clump or migrate from the treatment site and need to be surgically removed. Chemical peels can cause scarring or, in rare circumstances, someone could have a serious allergic reaction.

  If the treatment or procedure carries any risk — however small — it's important not to advertise it in a way that trivialises the decision to undergo it. Ads shouldn’t give the impression that it’s a decision to be taken lightly.

  In the past, the ASA has ruled that ads for non-surgical cosmetic treatments using phrases like “20-minute procedure that can be performed on your lunch break” or “If you can pinch it, we can treat it” were irresponsible for trivialising the decision to have treatment.

  2. Time-limited offers

  Just as the decision to have a non-surgical cosmetic intervention shouldn’t be trivialised, potential customers shouldn’t be rushed into it either — they should have plenty of time to consider their options.

  By nature, most promotions — whether a sales or prize promotion — are time-limited. While it’s possible to run a responsible promotion for a cosmetic treatment, you must take extra care.

  Avoid anything that uses time pressure to encourage quick decisions. In other words, don’t include short response times, or phrases like “Hurry, offer ends at midnight” or “Only three days remaining”.

  You’ll also want to take steps to avoid customers encountering the offer too close to the deadline — where they might not have time to weigh it up. For example, you could archive the page with the offer so it’s only accessible to people who received it by email at the beginning of the promotion.

  3. Cosmetic interventions as prizes

  There’s nothing in the advertising rules that says you can’t offer a non-surgical cosmetic treatment as a prize — but you must do so responsibly.

  The ASA is likely to look more favourably on a promotion if it’s made clear that it includes a strict consultation process first, and that the prize will only be awarded if the winner is deemed suitable for treatment after that consultation.

  You should also ensure the promotion doesn’t trivialise the decision to have the treatment, or encourage people to enter without understanding what’s involved.

  We strongly advise that if you’re thinking about running this kind of prize promotion, you contact our Copy Advice team first so they can help you plan it responsibly.

  4. Don’t play on people’s insecurities

  Finally, it’s important your ads don’t play on — or exploit — people’s insecurities.

  If you're preparing a responsible ad to promote your non-surgical cosmetic treatment or procedure, avoid messaging that suggests people aren’t good enough as they are, or that reinforces negative body image.

  We hope that’s a useful round-up of some of the key things to consider when putting together a responsible ad.

  Stay tuned for our next video on production techniques and before-and-after photos.

  If you want more help, you’ll find links to further guidance in the description box below — along with contact details for our Copy Advice team, who’ll be happy to help.

• 

  Before-and-after photos

  In this video, we’re going to talk about before-and-after photos and the use of production techniques on those images.

  Before-and-after photos are a popular way to show customers the effectiveness of your non-surgical cosmetic treatments. But in advertising — especially for these kinds of treatments — they can be considered a visual claim about how effective a treatment will be.

  The ASA has upheld many complaints about before-and-after photos that exaggerated the effectiveness of a product or treatment. But sit tight — over the next couple of minutes we’ll cover the key rules you need to know, from taking and editing photos to using them in ads or on your website.

  Before-and-after photos

  One: If you're planning to use before-and-after photos in your marketing, you must hold signed and dated proof that the photos are genuine and haven’t been digitally altered.

  Two: Because photos can be taken as visual claims, the images alone won’t be enough to support the impression they create. You’ll likely need additional evidence to back up the effectiveness of the treatment implied.

  You can find out more about the kind of evidence you’ll need by following the links in the description box below.

  Production techniques

  The advertising rules don’t just apply to the photos themselves — they also apply to the production techniques used on those images.

  There are generally two categories:

  • Pre-production — things like make-up, hair, lighting and staging before the photo is taken
  • Post-production — any digital editing done after the photo is taken

  The main principle is that neither pre- nor post-production techniques should mislead by exaggerating the effect of the treatment alone.

  For example, if you’re using dermal fillers to reduce fine lines and wrinkles, you can’t use Photoshop or other digital enhancements on the “after” photo to smooth the model’s skin. Similarly, you can’t use concealer in the “after” image for a laser acne treatment — this would give a misleading impression of the results.

  As a rule of thumb: don’t enhance or retouch any areas of the photo related to the treatment, as it may be difficult to prove the ad isn’t misleading.

  Disclaimers aren’t enough

  Adding a caption or disclaimer like “filter used” or “digitally enhanced” probably won’t be enough to fix a misleading impression. Disclaimers rarely override the overall impression of an ad — so using filters or Photoshop is still likely to breach the rules.

  Keep a record

  Just like with the images themselves, you should keep a clear record of any production techniques used.

  That includes photo documentation of what the person and image looked like before any pre- or post-production. If you can’t show what was done, the ASA may consider the ad or image to be misleading.

  A note on social media filters

  In 2021, the ASA ruled that two influencer posts broke the rules by using beauty filters in their Instagram Stories to promote tanning products. The filters made their skin appear more tanned than it actually was.

  This matters for cosmetic treatments, too. We advise against using filters on photos or videos where they could exaggerate the effect of your treatment.

  Even if you’re working with an influencer, you’re still responsible for the ad. It’s worth including a clause in any commercial agreement stating that filters or enhancements shouldn’t be used if they could mislead.

  We hope you found this video helpful. You’ll find links to further advice in the description box below.

  Stay tuned for our next video — on how to avoid misleading advertising claims.

• 

  Misleading advertising claims

  Welcome to the fourth video in this CAP Bitesize series — this one’s all about misleadingness.

  While the ASA does take action on harmful or offensive ads, the majority of our work – roughly 70% – is actually about tackling misleading claims.

  In this video, we’ll cover some top tips to help you avoid misleading advertising when promoting non-surgical cosmetic treatments.

  1. Don’t mislead or exaggerate

  It’s important to give a realistic impression of how effective your treatment will be.

  Make sure that any claims – whether written, visual or implied – reflect what can typically be achieved by the average customer.

  2. Be transparent

  Be clear about who will be administering the treatment, their qualifications and where it will take place.

  Don’t claim or imply that the person delivering the treatment is a medical professional, or regulated by a professional body, if that’s not the case.

  If you reference someone’s qualifications, you must hold evidence of those qualifications.

  Likewise, don’t suggest the procedure will take place in a regulated clinical setting if it won’t.

  3. Be clear on pricing

  Nothing annoys customers more than hidden charges.

  Make sure the prices you list relate clearly to the advertised treatments, and include all non-optional charges – like booking fees or deposits.

  If the final cost depends on the outcome of a consultation, be upfront about that – and explain how the cost will be calculated.

  4. Check your testimonials

  If you’re using customer reviews or testimonials to promote your services, they must:

  • Relate to the treatment being advertised
  • Be genuine (you must hold evidence)
  • Avoid making unsubstantiated claims

  For example, if a testimonial says “I lost six inches of belly fat with this treatment”, you must ensure that kind of claim is not misleading.

  Those are just a few of the key things to keep in mind.

  And remember – it’s always worth taking a step back and looking at your ads through the eyes of a potential customer.

  Stay tuned – in the next video, we’ll be covering the specific rules that apply to Botox and other prescription-only equivalents.

• 

  The advertising rules for Botox

  We’ve created this separate video about Botox because it’s different from all the other non-surgical cosmetic treatments we’ve covered so far.

  Before we get started, it’s worth noting that everything we’re about to cover applies to all prescription-only botulinum toxin injectables – but we’ll be using “Botox” as shorthand throughout.

  Botox is a prescription-only medicine

  Because Botox is a prescription-only medicine (POM), it’s subject to separate rules – and cannot be advertised to the public, full stop.

  The UK advertising rules here are very strict. The ASA will consider almost any reference to Botox – direct or indirect – as likely to breach the rules.

  This applies to all media:

  • Print, leaflets, brochures, posters
  • Online content, including social media
  • Even hashtags

  And remember: it’s not just paid-for ads. Posts on your own social media channels or website also count as ads.

  Promotions and giveaways

  You must not include Botox in any kind of promotion:

  • Not in a price promotion (like a discount or special offer)
  • Not in a prize promotion (like a giveaway)

  What about websites?

  There is a narrow exception – and that’s websites.

  You can mention Botox on your website, but only in very limited, specific circumstances. The principle is: a consumer casually browsing your site should not be able to find any reference to Botox easily.

  That means:

  • No mention on your homepage
  • No mention in hover text, small print or testimonials
  • No mention in your price list (unless suitably gated)

  You can refer to Botox as a possible treatment option following a consultation – for example, for fine lines and wrinkles – as long as the treatment will only be offered if the customer is deemed suitable.

  How to present this on your site

  Here’s a safer approach:

  • Advertise the consultation (not the treatment) on your homepage.
  • From there, link to a separate page with more information about the consultation.
  • That page can then link to a further page (ideally two clicks from the homepage) which includes factual, balanced information about treatment options – including Botox.

  Any information about Botox must reflect what’s in the patient information leaflet – no promotional language, no exaggeration.

  Price lists

  You can mention Botox in a price list as part of a broader range of treatments – but only after the user has clicked through the consultation pages. They shouldn’t be able to view pricing for Botox directly from the homepage.

  The key thing to remember is: you are promoting the consultation, not the treatment.

  Making sure users can’t access information about Botox without going through the consultation journey is essential for compliance.

  That’s a summary of the key rules you need to know about advertising Botox.

  We’ve included links to more information in the description box below – and if you have any questions, our Copy Advice team will be happy to help. You’ll find their contact details below too.