You’ve no doubt noticed that ASA (the advertising standards authority) have cracked down on Botox. As a prescription-only medicine, it cannot be advertised directly to the public and that means your patients. When it’s a service that you provide, where does this leave you? Can you talk about it at all?
After going through the vast amount of guidance available on what’s considered a breach in rule 12.12 of the CAP Code, I’ve drilled down four things that you need to avoid.
The main issue that ASA have is with the word itself. It can’t be used on website homepages, marketing collateral and social media posts. This covers the brand Botox as well as other brands of Botulinum toxin, Vistabel, Dysport, Bocouture, and Azzalure.
This may seem a bit strict, but in online marketing, words are pretty powerful, especially searchable ones. Using these words in any way, shape or form in a way that could result in your patients finding the service on your website is considered as advertising the product, so is not allowed.
You can still talk about the treatment, but if you do, it has to be facts only. This means you may need to reword what you have on your site.
This is what ASA say about text on websites:
In the context of a website, very limited references to Botox may be acceptable as long as they do not appear on the home page and claims do not go beyond balanced and factual information typically found in the patient information leaflet, ‘Summary of Product Characteristics’ or similar non-promotional information that comes with the product. Casually browsing consumers must not be able to come across information relating to Botox or other POMs with ease.
This means that language that’s considered persuasive and emotive is out.
Example:
Reverse the signs of ageing with anti-wrinkle treatments. Enjoy a boost of self-confidence as those wrinkles are smoothed away.
This type of language is regarded as persuasive because it focuses on the benefits. It’s verb-driven and active, driving attention to what the product does, rather than what the product is. Anything written with this intention, to actively persuade the reader to go for the treatment, can not be used.
Text that you can use has to stick within the parameters of the Summary of Product Characteristics. You can say what Botox is, what it does and how it is used. You can’t say what it will treat – so anything referring to hyperhidrosis, platysmal wrinkles, migraines etc can’t be used. While Botox is proven to treat these conditions and can be prescribed as such, it can’t be advertised this way. Those parts of the discussion should happen between the patient and the prescriber, not the user and advertiser.
It’s not all doom and gloom. While you can’t advertise Botox, you can advertise yourselves. The ASA advise that instead of advertising Botox, you should instead advertise the consultation service. So here’s an example of this:
Wrinkles are an inevitable part of life. We offer treatments that can help tackle these lines. Our qualified specialists are best suited to give you advice on what treatment will work best for you. Get in touch to arrange a consultation with our clinician.
While you and I know that Botox is one of these treatments, the reader doesn’t necessarily know. It groups Botox with the non-POMS (fillers, skin peels etc). Here, the focus is on the consultation service, not the treatments.
Speak to us. We can get your website compliant again and help you to market your services in a way that doesn’t step on toes, but still drives the results home. Our team have all been briefed in these changes and know the guidance inside out. We can also speak to the CAP on your behalf and get their advice too.
Sample copy for facial aesthetics that can be used online
Facial Aesthetics – sample copy
Read the ASA guidance on advertising Botox
https://www.asa.org.uk/advice-online/beauty-and-cosmetics-botulinum-toxin-products.html
https://www.asa.org.uk/news/a-fine-line-the-dos-and-don-ts-of-advertising-botox.html
Read the Patient Leaflet on Botox
https://www.medicines.org.uk/emc/files/pil.859.pdf