The Joint Council for Cosmetic Practitioners (JCCP) has issued guidance on the advertising of prescription-only medicines (POMs), following concerns about non-compliant promotional activity by aesthetic practitioners. The guidance highlights particular concerns around botulinum toxin advertising, including references to POMs on clinic websites and social media.
The JCCP has highlighted key requirements for aesthetic practitioners advertising prescription-only medicines (POMs), including botulinum toxin. We have examined what practitioners can and cannot reference on websites and social media, how pricing should be presented, and the potential consequences of non-compliant advertising.
What are the rules for advertising prescription-only medicines (POMs) in the UK?
The Human Medicines Regulations (2012) restrict the promotion of POMs in law and this is enforced by the MHRA, and by the Advertising Standards Authority (ASA) against the CAP code.
Prescription-only medicines (POMs), including botulinum toxin products, must not be advertised to the public in any format, including printed literature, social media postings and on websites.
Aesthetic practitioners can promote the services as long as they don’t reference a POM, directly or indirectly.
How can aesthetic practitioners discuss prescription-only medicines (POMs) on their websites?
It is against the regulations to reference POMs on the homepage of your website, and any references to POMs must promote the consultation on a separate page.
What counts as a direct and indirect reference to prescription-only medicines (POMs)?
A direct reference to POMs includes referring to brand names, such as ‘Botox®’ or generic references such as ‘botulinum toxins’.
Whereas an indirect reference is terminology that ‘infers’ that a particular medicine is intended, such as anti-wrinkle injections, when discussed alongside other terminology referencing price per area, or with before-and-after photographs which demonstrate the effect of a POM.
Can aesthetic practitioners advertise the price of prescription-only medicines (POMs)?
Aesthetic practitioners can discuss pricing of POMs, but not in the regular pricing structure.
The JCCP recommends advertising with consultation-led pricing, for example: “Prices from £X. Following a consultation with a prescriber, each patient will receive an individual assessment, prescription (where appropriate), treatment plan and quotation.”
How can aesthetic practitioners share educational content about prescription-only medicines (POMs)?
Educational material published by a practitioner may still be considered advertising if it contextually promotes a prescription-only medicine.
Practitioners should be cautious when producing content discussing:
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How botulinum toxin works
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Treatment indications
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Benefits of treatment
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Potential complications
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Before and after images.
What does the JCCP guidance say about POM advertising?
The JCCP has advised that clinic homepages can provide an overview of the services offered, and in the case of POMs, services must link to a second page providing more information about the consultation.
It is also recommended that A member of the public must be able to consider this information before choosing to review further medicine-specific information. To achieve this, a link to a third page is recommended to provide all the information about the POM.
Common prescription-only medicines (POMs) used in aesthetic practice
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Botulinum toxin
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Hyaluronidase, for example ‘dissolve & refill’
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‘Filler dissolve’
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Intramuscular corticosteroid ("hay fever") injections
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Prescription-only Vitamin B12 preparations
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Local anaesthetic injections
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Prescription weight loss medicines
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Intravenous drips
How does the JCCP enforce POM advertising regulations?
The JCCP routinely audits registrants’ websites and social media activity.
Where non-compliant POM advertising is identified, registrants may be asked to amend or remove the content.
Continued non-compliance could have implications for JCCP registration, with serious or ongoing breaches potentially referred to regulators including the ASA and MHRA.
JCCP compliance checklist
Before publishing any marketing material, ask yourself:
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Does this advertise directly or indirectly promote a prescription-only medicine?
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Does it use terminology that patients associate with botulinum toxin?
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Does it include pricing or offers that could promote a POM?
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Could educational content be interpreted as encouraging patients to seek
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treatment?
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Is the focus on promoting the medicine rather than the consultation and
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professional assessment?
If the answer to any of these questions is "yes", review the content against the JCCP Policy, ASA and CAP guidance before publication.
FAQ’s
Can aesthetic practitioners advertise prescription-only medicines (POMs) in the UK?
No. Prescription-only medicines (POMs), including botulinum toxin, must not be advertised to the public in the UK. This applies to websites, social media, printed materials and other forms of public advertising.
Can aesthetic practitioners mention Botox or botulinum toxin on their website?
Aesthetic practitioners should not directly advertise or promote prescription-only medicines to the public. JCCP guidance highlights particular concerns about references to POMs on website homepages and recommends that information is structured around the consultation and professional assessment.
Can aesthetic practitioners advertise the price of POM treatments?
POMs should not be promoted through standard treatment pricing or offers that encourage patients to seek a particular medicine. The JCCP recommends consultation-led pricing, where an individual assessment is undertaken before a prescription, treatment plan and quotation are provided where appropriate.
Can educational content about POMs be considered advertising?
Yes. Educational content can still be considered advertising if, in context, it promotes a prescription-only medicine. Practitioners should therefore take care when discussing how botulinum toxin works, treatment indications, benefits, complications and before-and-after images.
Can aesthetic practitioners advertise anti-wrinkle injections?
Practitioners should consider whether wording such as “anti-wrinkle injections”, together with pricing, imagery or other contextual information, indirectly identifies or promotes a prescription-only medicine. The overall context of the advertising is important when determining whether content could constitute promotion of a POM.
What happens if an aesthetic practitioner breaches POM advertising rules?
The JCCP routinely audits registrants’ websites and social media activity. Where non-compliant advertising is identified, registrants may be asked to amend or remove the content. Continued non-compliance could have implications for JCCP registration, and non-compliant promotional activity may be referred to relevant regulators, including the ASA and MHRA.
