TGA crackdown on skin health ‘influencers’ long overdue, experts say


By Michael Woodhead

10 Mar 2022

Researchers have welcomed the  Therapeutic Goods Administration’s release of a social media advertising code that will crack down on social media influencers promoting therapeutic skincare products and surgical implants.

The TGA guide warns that statements and testimonials relating to skincare and beauty products such as: ‘fades age spots’ and ‘removes toxins’ are therapeutic claims and will be subject to TGA regulations.

“A social media post that promotes the use or supply of therapeutic goods is an advertisement,” it emphasises.

“Whether an advertisement for therapeutic goods appears on social media or in any other media, the advertisement must comply with therapeutic goods legislation.”

In its tips for social media influencers, the TGA says that anyone who is involved with a therapeutic goods company, such as being paid or given a product by the company to promote their goods, should think carefully about what they post online and seek legal advice if unsure.

“Your social media posts may have an impact on your followers’ beliefs, attitudes, preferences and behaviours. Your comments about therapeutic goods can influence consumers’ choices. Therapeutic goods should be chosen on the basis of clinical need, not through the persuasion of influencers,” it said.

“Any comments you make about your personal experience with therapeutic goods amounts to a testimonial. Testimonials are not permitted by those involved in the production, sale, supply or marketing of the goods. This includes influencers who are engaged by a therapeutic goods company to promote the goods.”

The code follows a number of reports highlighting the role of influencers in promoting inappropriate skin health products and practices.

A review of acne treatments discussed on social media published in February showed that the vast majority of the content was generated by influencers, retailers and non-dermatologist providers, with dermatologists  accounting for  less than 4% of the content. Of the 124 separate ingredients mentioned as potential acne treatments only 11% were supported by high quality evidence.

Dr Yousuf Mohammed, Research Fellow at the University of Queensland’s Diamantina Institute said recent media investigations had highlighted how influencers were a key strategy used by the cosmetic and beauty industry to influence consumers, and promoted inappropriate therapies and unhealthy trends such as body dysmorphic disorder.

“We welcome the decision from TGA to update the Therapeutic Goods Advertising Code cracking down on paid/incentivised promotion. We believe this was necessary and a long time coming.,” he said.

“Unsolicited health advice by non-professional entities can have damaging health impacts. This is of particular importance where formulation and device combinations such as dermaroller and skin products are concerned. This can be incredibly dangerous and is not licensed for home use in most countries.”

Dr Marc Cheong, Senior Lecturer in Information Systems (Digital Ethics), at the University of Melbourne said the TGA’s social media advertising rules were a step in the right direction, to guide influencers in ‘doing the right thing’.

“In today’s social media landscape, social media ‘influencers’ – on platforms such as YouTube, Instagram, and TikTok — can amass a huge following, thanks in part to the asymmetric nature of these social media platforms as well as algorithmic personalisation and recommender systems,” he said.

“Influencers can engage their audience with rich media content which may include product endorsements and giveaways. Due to their extensive potential for engagement, which is well beyond those of a typical non-celebrity social media user, influencers thus have a greater responsibility (or ethical duty) to avoid any (unintended) harm that their product endorsements can cause to their followers. This includes any possibility of harm to one’s health as a consequence of endorsing a health-related product, given that influencers may not have the medical expertise to scrutinise said product in its entirety.”

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