Tighter rules for fillers and facefixers

I recently wrote an article which appeared in the Gold Coast Bulletin under the heading Tighter rules for fillers and face fixers.

Regulatory bodies including AHPRA, the TGA, and Queensland Health, have clarified how existing regulations are interpreted this year.

Many in the industry have been concerned for some time that very large corporations (some prescribing for over 1,000 nurses) have been supplying nurses with schedule 4 drugs and injectables in potentially an unethical, unsafe and possibly illegal manner.

These companies use doctors who often provide rapid and perfunctory telehealth consultations to tick the boxes for prescribing, and there is evidence that in some cases these doctors are not experienced in cosmetic medicine and have inadequate insurance.

Many view this as improved protection for patients and agree with the Medical and Nursing board statement that injectable drugs should not be prescribed to a patient without a proper assessment by the prescriber – which includes a face to face consultation.

Fortunately there is also a move in cosmetic injectables away from over-filling and the over enhancement of features toward a more natural look with excellent skin quality.

This is a welcome change as it is something Envisage Clinic has been espousing for many years. We have always recommended conservative treatments so that you look good – but not “done”.

The article by Anne Wason Moore was published in The Gold Coast Bulleting on June 14th,  I’ve provided a summary for you below:

Summary: Tighter Rules for Cosmetic Injectables in Australia

Industry Concerns

• The cosmetic industry is alarmed by new national regulations issued by the Australian Health Practitioner Regulation Agency (AHPRA).
• The $4.1 billion non-surgical cosmetic sector faces increased oversight, particularly around training, advertising, and prescribing practices.
• Practitioners fear disruption, with many clinics—especially in Queensland—struggling to adapt.

Key Regulatory Changes

• Batch prescribing of Schedule 4 drugs (e.g., Botox) is now restricted—each patient must have a personal consultation (video or in-person).
• The prescriber is now fully responsible for patient safety, regardless of who performs the procedure.
• Patients must receive written details about:
  • The prescriber and injector
  • Product information
  • After-care instructions
• Advertising rules are tighter: no testimonials from influencers and a clampdown on misleading claims.
• Practitioners must meet higher minimum training standards.
• Clinics must screen for underlying conditions like body dysmorphic disorder and ensure patients have realistic expectations.

Queensland-Specific Regulations

• Stricter than national rules: clinics must either have a doctor or prescribing nurse practitioner onsite, or only store individually dispensed medications.
• Affects an estimated 80–90% of clinics, many of which are nurse-run and use telehealth “scripting” services.
• These changes could potentially increase costs and push patients toward unregulated, black-market providers.

Industry Voices

• Dr. Christopher Leat (Envisage Cosmetic Clinic) supports the changes overall, stating they enhance safety and clarity, though he acknowledges the confusion and administrative burden.
• He criticizes bulk “scripting” services where nurses use third-party telehealth doctors to prescribe treatments without being present.
• Advocates like Queensland Aesthetic Nurses United (QANU) have protested, arguing the changes unfairly penalize nurse-led clinics.

Background and Stats

• AHPRA’s cosmetic surgery hotline (since 2022):
  • Received 1282 calls
  • Logged 472 formal complaints
• Issues reported include:
  • Permanent nerve damage
  • Strokes from cosmetic injectables
  • Predatory marketing to minors
  • Poor training and 52-second telehealth consultations