Medicines in beauty treatment and cosmetic injectable businesses

There have been no changes to the Medicines and Poisons Act 2019 (Qld) (MPA) and Medicines and Poisons (Medicines) Regulation 2021 (Qld) (MPMR) relevant to medicines used in the cosmetic industry, since these laws commenced in September 2021.

During routine compliance activities undertaken by Queensland Health, it became evident that further guidance for the industry was required. A fact sheet was released in December 2024 to support industry to better understand the requirements of the existing legislative framework in Queensland. Following subsequent engagement with industry, a revised fact sheet has been published to clarify some aspects of the legislation and provide details of compliant business models.

The controls around medicines are in place to prevent harm to the public by ensuring they are managed in an appropriate, effective and safe way. This is reflective of the purposes of the MPA.

No, these controls apply broadly to Schedule 4 ‘prescription-only’ medicines in Queensland. To ensure health risks arising from the use of the substances are appropriately managed, only certain persons are authorised under the MPA to buy, possess, prescribe, administer and dispense medicines.

Queensland Health understands that some instances of non-compliance in the industry are not necessarily deliberate. In the first instance, depending on the severity of the non-compliance, our approach will be to educate clinics on how to become compliant.

Clinics should ensure they are meeting the requirements of the legislation. The revised factsheet provides additional guidance on permitted activities and compliant business models. If any more information is required, clinics can engage with Queensland Health for further guidance and support to achieve compliance.

No. RNs are not authorised under the legislation to buy stock of S4 medicines for these businesses/clinics. RNs are authorised under the MPMR to buy medicines listed in the Extended Practice Authority called ‘Registered Nurses’, however, this does not include S4 medicines used for beauty treatment/cosmetic businesses/clinics.

No. The action of 'ordering' S4 medicines constitutes buying of the S4 medicines under the MPA, because it is attempting to obtain the medicine, whether or not payment is made. RNs are not authorised to buy stock of S4 medicines for their clinics, and administrative staff are not authorised to buy stock of S4 medicines.

No. Doctors cannot buy stock of S4 medicines for a clinic where they do not have exclusive custody and control of the medicines. Doing so would constitute supplying the S4 medicines to persons, such as RNs, who are not authorised to buy the S4 medicines, or to possess the S4 medicines as stock.

The MPA and MPMR do not prohibit doctors and Nurse Practitioners (NPs) from consulting with clients via telehealth, including if the doctor or NP subsequently lawfully prescribes S4 medicines for the clients they consult with.

The revised factsheet provides additional guidance on permitted activities and compliant business models.

‘Dispense’ means to sell a medicine on prescription, and in Queensland only pharmacists and medical practitioners (doctors) are authorised to dispense cosmetic injectable medicines.

Medicines can only be dispensed from lawfully obtained stock, which in Queensland means stock bought on a purchase order.

Dispensing of medicines in Queensland must be compliant with Chapter 4, Part 8 of the MPMR, including dispensing on a lawful prescription. Dispensed medicines must also have a label affixed that meets the requirements for a dispensing label in the Commonwealth Poisons Standard, Appendix L.

There may be other restrictions in other States or Territories and there may also be professional practice limitations.

Yes. A dispensing doctor or pharmacist may send the medicine (dispensed and labelled for an individual client) via an employee or courier, acting as an ‘agent’ for the client, directly to the clinic where the client will have the medicine administered.

It is preferrable that cosmetic injectables are not given directly to the client, due to the risks of self-injecting or injecting by untrained persons, and also to maintain cold chain requirements for the medicine.

To facilitate this, doctors and NPs prescribing medicines to be dispensed and used in clinics by RNs should ensure that the prescription includes instructions similar to the following: "NOT TO BE GIVEN DIRECTLY TO PATIENT NOR FOR ADMINISTRATION BY PATIENT. MUST BE SENT DIRECTLY TO <CLINIC NAME> ONLY FOR ADMINISTRATION BY AN AUTHORISED HEALTH PRACTITIONER."

Each State and Territory has its own laws that govern how medicines must be handled in that State or Territory. Queensland's MPA and MPMR detail the authorities and limitations relevant to regulated substances placed on different health professionals in Queensland.

In Queensland, RNs cannot possess a stock of S4 medicines for use in their clinics.

However, RNs may hold individually dispensed medicines for individual clients.

Queensland Health will continue to engage with industry to develop a greater understanding of the issues and compliant practises.

We are committed to working closely with industry to support clinics, wholesalers and prescribers to achieve compliance.