Why we can't name it: the law on advertising anti-wrinkle injections

People ask, reasonably often, why the website is so careful with its language. Why it says "anti-wrinkle injections" rather than the name everyone actually uses. Why there is no price next to it on the price list. Why there are no before-and-after photographs anywhere on the site.

The short answer is that the product used is a prescription-only medicine, and in the United Kingdom it is against the law to advertise a prescription-only medicine to the public. The longer answer is worth setting out, because the rule shapes how this website is written.

The rule itself

The governing law is the Human Medicines Regulations 2012. Regulation 279 prohibits the advertising of prescription-only medicines to the general public. It is a criminal offence, enforced by the Medicines and Healthcare products Regulatory Agency, and it applies to every clinic, every practitioner and every website in the country.

The injectable used to soften lines of expression is prescription-only. It can only be prescribed by a qualified prescriber, after an assessment of the individual patient. That is why a consultation is not a sales formality here: legally, it is the point at which a prescribing decision is made.

Alongside the law sits the advertising code. Rule 12.12 of the CAP Code, which the Advertising Standards Authority enforces, says plainly that prescription-only medicines may not be advertised to the public. The ASA and the MHRA work in parallel: one can rule an advertisement in breach, the other can prosecute.

What that means in practice

Describing the treatment generically is permitted. "Anti-wrinkle injections" is a description of a procedure, and a clinic may say it offers that procedure, explain what it involves, and set out who it suits. What a clinic may not do is name the medicine.

This is a genuine distinction rather than a technicality. The law is aimed at stopping the public being marketed a specific medicine directly, on the basis that the decision to use a particular drug should be made by a prescriber with the patient in front of them, not by an advertisement.

So on this site you will find a page describing anti-wrinkle injections in some detail — what they do, what they do not do, who they are not suitable for, what happens on the day. What you will not find is the brand name, because printing it here would be advertising the medicine to you.

Why workarounds do not work

A great deal of ingenuity has gone into trying to name the product without naming it. Deliberate misspellings with an asterisk or a zero. Abbreviations. Affectionate nicknames. Emoji standing in for letters. Hashtags that spell it out. The phrase "baby" attached to a shortened form.

The ASA has considered these and ruled consistently that they breach the rule. The test is not whether the exact word appears; it is whether the audience would understand which medicine is being referred to. If they would, it is an advertisement for that medicine. Rulings have been made against clinics, against individual practitioners, and against influencers posting about their own treatment.

The same logic catches indirect references, such as a post that does not name the product but is unmistakably about it, or a price list entry that uses a nickname.

Why there are no before-and-after photographs

A before-and-after image of a treatment carried out with a prescription-only medicine is, in the regulator's view, an advertisement for that medicine. It communicates that a particular product produces a particular result more directly than any sentence could.

There is a second reason, independent of the law. Photographs of one person's face at two moments in time are a poor guide to what will happen to yours. Lighting, expression, angle, camera, time of day and the ordinary variation in a face between two mornings all move the picture. A result that is genuinely good can be made to look modest, and a result that is modest can be made to look transformative, without anyone editing anything.

We would rather describe honestly what a treatment does and does not do, and let the consultation do the work of setting expectations for your face specifically.

Price, and why it is handled carefully

Advertising a prescription-only medicine includes promoting it by price. Clinics take different views on where the line falls between pricing a procedure and pricing a medicine. Our position is the cautious one: the price list covers the treatments we can price openly, and for anti-wrinkle injections the cost is discussed at consultation, once there is an assessment and a plan.

The consultation fee is redeemable against treatment, and the figure is published on the price list.

The other rules worth knowing

Two more pieces of law shape how this treatment is offered in England.

The Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 made it a criminal offence to administer these injections, or dermal fillers, to anyone under 18 for a cosmetic purpose. It is also an offence to make the arrangements, so a booking taken knowingly is itself unlawful. There is an exception only where the treatment is provided by a doctor, or under their direction, for a medical reason.

The Health and Care Act 2022 gave the government the power to introduce a licensing scheme for non-surgical cosmetic procedures in England. Consultation on that scheme has taken place and the detail is still being settled. When it arrives it is likely to set national standards for who may perform which procedures and in what premises.

Separately, professional regulators expect that a prescriber assesses the patient in person before prescribing. Remote prescribing of these injections, where a prescription is issued without the prescriber having seen you, is not considered acceptable practice.

What this should tell you as a patient

The rules exist because a prescription-only medicine should be chosen for you by someone who has examined you, and because a face is not a product photograph.

The practical value of knowing the rule is that any clinic's advertising becomes easier to read. The same rules sit alongside those on consent, record-keeping and who may administer the treatment, and a clinic that follows one set tends to follow the others.

This article is general information about UK advertising and medicines rules as they stood on the review date above. It is not legal advice. The rules change, and the licensing scheme in particular is still developing.

Why does the site say "anti-wrinkle injections" instead of the brand name?

Because the product is a prescription-only medicine, and UK law prohibits advertising prescription-only medicines to the public. Describing the procedure generically is allowed; naming the medicine is not.

Is it actually illegal, or just against advertising guidelines?

Both. The Human Medicines Regulations 2012 make it a criminal offence, enforced by the MHRA. The CAP Code, enforced by the Advertising Standards Authority, contains a parallel rule.

Can a clinic get around it by misspelling the name?

No. The ASA's test is whether the audience would understand which medicine is meant. Misspellings, abbreviations, nicknames and emoji have all been ruled in breach.

Why won't you show me before-and-after photographs?

They are treated as advertising the prescription-only medicine. Separately, they are a poor guide to your own result, because lighting, angle and expression move the picture more than most people expect.

Why isn't there a price for anti-wrinkle injections on the price list?

Promoting a prescription-only medicine by price falls within the advertising restriction. The cost is discussed at consultation, once there is an assessment and a plan. The consultation fee itself is published.

Can under-18s have this treatment?

Not for cosmetic reasons in England. Since 2021 it has been a criminal offence to administer these injections, or dermal fillers, to under-18s cosmetically, and an offence to arrange it. A narrow exception exists for treatment given by or under the direction of a doctor for a medical reason.