ASA rules against 'Botox models' advertisements

Social media can be a very effective tool to market your aesthetic business to potential clients. Yet, an increase in challenges by The Joint Council for Cosmetic Practitioners (JCCP) and a rise in ASA rulings against clinics for the marketing of prescription-only medicines to the public demonstrates that practitioners need to better understand the legal parameters when advertising online.

Those considering marketing a need for 'Botox models' – aka volunteer patients that practitioners use for injectable training and courses in exchange for free or discounted procedures – should be especially careful.

In June 2023, the ASA upheld a ruling against Menar Jimmy Georgiou for an advertisement posted in September 2022, on the Facebook page titled "UK AESTHETICS & BEAUTY MODELS WANTED". It stated, "Models wanted for the following treatments … Botox … B12 injections."

The advert was challenged by the JCCP for breaching regulations against advertising prescription-only medicines (POMs) to the public (CAP Code (Edition 12) rule 12.12 (Medicines, medical devices, health-related products and beauty products). This serves as a reminder to practitioners that "Botox and B12 injections [are] POMs" and therefore cannot be advertised on public Facebook groups.

Significantly, this case also demonstrates the need for practitioners to respond to any enquiries from the ASA too. Menar Jimmy Georgiou did not do so, which demonstrated an "apparent disregard for the Code", resulting in a breach of CAP Code (Edition 12) rule 1.7 (Unreasonable delay) that was referred to the CAP's Compliance team.

For more information and advice about advertising within the aesthetic industry, visit asa.org.uk