Medicines in beauty treatment and cosmetic injectable businesses

Schedule 4 cosmetic injectables are strictly regulated in Queensland. Practitioners, clinics and suppliers must adhere to the Medicines and Poisons Act 2019 (MPA) and Medicines and Poisons (Medicines) Regulations 2021 (MPMR) to ensure patient safety and compliance with the law.

The MPA and MPMR contain provisions which regulate the buying, storing, prescribing and use of Schedule 4 (S4) medicines, which includes S4 cosmetic injectables used in cosmetic business settings. All cosmetic injectable businesses operating within Queensland must follow these laws, including businesses who use services which are based interstate.

More detailed information is available in the Medicines in beauty treatment/cosmetic businesses fact sheet (PDF 146 kB) and frequently asked questions.

Medicines commonly used in beauty treatments by cosmetic injectable businesses include botulinum toxin (sold under the brand names Botox® and Dysport®) and dermal fillers such as collagen, hyaluronic acid and polylactic acid. These substances are classified as S4 prescription only medicines.

Prescribing and administering S4 cosmetic injectables

Medical practitioners (doctors) or nurse practitioners (NPs) are authorised to prescribe S4 cosmetic injectables in a beauty/cosmetic setting, only if the S4 cosmetic injectable is reasonably necessary for the therapeutic treatment of the client (section 81 of the MPMR).

For more information on prescriptions, please refer to the Writing lawful prescriptions factsheet (PDF 202 kB).

Standing orders

Standing orders cannot be used for the administration of S4 cosmetic injectables to clients by registered nurses (RNs) in beauty treatment/cosmetic business.

For more information on standing orders, please refer to Standing orders factsheet (PDF 126 kB).

Buying S4 cosmetic injectables

Only doctors or NPs may buy S4 cosmetic injectable medicines to be held in stock for use in a beauty treatment/cosmetic clinic at which they are physically present to have exclusive custody and control of the medicines.

Supplying S4 cosmetic injectables

Suppliers such as a licensed medicine wholesaler or pharmacist, can only supply S4 cosmetic injectables to a person who is authorised to buy the S4 cosmetic injectables. The authorised person must have the authority to give a purchase order under the MPMR, which includes a doctor or NP, but does not include a RN.

Possessing and storing S4 cosmetic injectables

S4 cosmetic injectables must be stored in a way such that they are not physically accessible by any person who is not authorised to possess them, because having access to the medicines means the person has possession of the medicines.

Permitted business models

  1. Where a doctor or NP has exclusive custody and control of S4 medicines at a clinic or joint custody and control of S4 medicines at a clinic with another doctor or NP.
    1. The doctor or NP may buy S4 medicines to hold as stock for use at that clinic.
    2. Following consultation with a client, the doctor or NP may prescribe an S4 cosmetic injectable medicine for:
      1. administration by a person authorised to administer the medicine, for example, an RN
      2. dispensing by a person authorised to dispense the medicine (a doctor or a pharmacist), which does not include a NP or an RN.
  2. Where a doctor or NP provides services to a nurse-led cosmetic injectables clinic from a 'remote' location (using dispensed S4 cosmetic injectable medicines)
    1. Following consultation with a client, which may include telehealth consultation, a doctor or NP may prescribe an S4 cosmetic injectable medicine for dispensing only.
    2. The S4 cosmetic injectable medicine may be dispensed by any doctor or pharmacist and taken/sent to the nurse-led clinic.
    3. The dispensed S4 cosmetic injectable medicine may subsequently be administered by a person at that clinic who is authorised to administer the medicine, including an RN, in accordance with the dispensing label.

Frequently asked questions

  • 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.

  • 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.

  • 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.

You can also download the frequently asked questions (PDF 173 kB).

Enquiries

For any enquiries, you can contact the Medicines Approval and Regulations Unit (MARU) at MARU@health.qld.gov.au.

Related topics

  • Infection control requirements
  • Buying and administering S2 and S3 medicines – only approved persons such as a doctor, NP or RN can buy stock or administer S2 or S3 medicines, such as numbing creams that contain lidocaine.
  • Advertising of S4 cosmetic injectables is not permitted. The Therapeutic Goods Administration (TGA) has strict controls on advertising. Further information is available on the Therapeutic Goods Administration Referring to cosmetic injectables in advertising page.

Last updated: 15 April 2025