Botox for Valentine's Day?

Posted on the 12 February 2010 at 12:31

I stumbled across this U.S. advert on the Internet today advertising Special Offers on Botox® and Dermal Fillers for Valentine's Day.



In the UK this advert would be frowned upon for two reasons:

  1. Although not illegal, promotion of certain cosmetic treatments performed by medical professionals using time limited offers linked to discounts or other incentives is deemed by some sections of the cosmetic industry to be an inappropriate form of marketing.
  2. In the UK, it is illegal to specifically advertise Botox® (or any other brand of botulinum toxin) on the web, or in magazines, local papers etc. as botulinum toxin is categorised as a prescription only medicine and it is currently illegal for a clinic to advertise any prescription medicines directly to the general public. This is not the case for most other cosmetic injectable treatments such as dermal fillers (e.g., Restylane or Juvéderm) which are currently classified as medical devices and not prescription medicines.

Many consumers (and indeed some clinics offering botulinum toxin injections) are unaware of this fact and the UK advertising authorities and the MHRA (Medicines and Healthcare products Regulatory Agency) who are trying to police the promotion of botulinum toxin are, in our view, fighting a losing battle. Just type Botox into a search engine and see how many websites use the word!

Even clinics aware of advertising regulations, who may use the words wrinkle relaxing, or wrinkle reducing injections in offline print adverts may still try and use the word Botox on their website as this is what consumers will search for on the web, and unless the word is mentioned somewhere in the clinic's website, it usually won't be found in natural search engine results.


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Blog Comment(s) [1]

It might be worth pointing out that the MHRA published a guidance paper on their site at:

Entitled 'New guidance on website advertising for medicines' it includes the following points:

"The Home page should focus on medical conditions and the service the website provides. It should avoid direct reference to named POMs. Links and navigation aids may be given for particular conditions and diseases but not to specific POMs. Hover text and any small print at the bottom of the home page should also not refer to specific POMs.

Further pages about the condition, which the consumer chooses to access, may contain information on specific medicines provided this is presented in the context of an overview of the treatment options."

It also states that:

"Competitive Tools (Meta-tags/ Meta-descriptions/ Meta-Keywords)
Our main focus is the content of the website, rather than the competitive tools used to increase awareness of the website which are not usually prominent in customer views."

The main difference between the draft formulation of the guidance and the final published version was the inclusion of the meta-tag section and another section recommending that website addresses which name specific POMs in their core URL should be avoided.

Julian Lumley