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Industry rules

Med spas and aesthetic clinics: 30 matched rules, 11 that block approval

The checker matches 30 rules to med spas and aesthetic clinics by what the rules are about: injectables, laser, cosmetic procedures and image comparisons. 4 rules that block elsewhere only warn on clinical service copy, so 11 block here. Most sit under disease claims (11), state law (6) and platform policy (5). State rules reach 2 states, and Connecticut has the most (3). Ad platform policy adds 5 rules that name 13 platforms.

The numbers for this industry

30

Matched rules

21 federal, 4 state, 5 platform

11

Block approval

4 more only warn for this copy

347

Shared rules

Run on all health copy, not listed here

4

State and platform pages

Only where the gate is met

Where the matched rules sit

  • Disease claims11
  • State law6
  • Platform policy5
  • Regulatory status3
  • Efficacy and proof2
  • Patient quotes and reviews2
  • Outcome statistics1

Rules that weigh most for med spas and aesthetic clinics

Federal and general rules first, blocking before warning, citations checked against stored text before the rest. Rules with their own page link there.

  1. CG-DIS-019 · Blocks approval · Citation checked against stored text

    Claims to slow, stop or prevent a serious disease, or to restore function after spinal cord injury, are disease claims that need drug approval and evidence.

    Source: FDCA 201(g)(1); 21 CFR 101.93(g); FDA consumer alerts on stem cell and dietary supplement disease claims; FTC Act section 5

    Safer wording: Remove disease slowing, prevention and recovery claims. Describe a supplement by its nutrients only, and a stem cell service only as an investigational study.

    21 CFR 101.93(g) · Needs counsel review

  2. CG-INF-001 · Blocks approval · Citation checked against stored text

    A free product, a commission or a code is a material connection that must be clearly disclosed, and a before-and-after claim by a paid endorser needs proof and a typical-results statement.

    Source: FTC Endorsement Guides, 16 CFR Part 255; FTC Rule on Consumer Reviews and Testimonials, 16 CFR Part 465; FTC Act section 5

    Safer wording: Put a clear disclosure of any payment, gift or commission at the start of the post, and remove unproven results claims.

    16 CFR Part 255, 16 CFR Part 465 · Needs counsel review

  3. CG-RFA-002 · Blocks approval · Citation checked against stored text

    Naming a disease as what a product, formula or package is for, or calling something a natural remedy for it, is an implied claim to treat or prevent that disease.

    Source: FDCA 201(g)(1); 21 CFR 101.93(g); FTC Health Products Compliance Guidance

    Safer wording: Do not name a disease as the use of a supplement or cosmetic. Describe general wellness support only.

    21 CFR 101.93(g) · Needs counsel review

  4. CG-RFA-003 · Blocks approval · Citation checked against stored text

    Anti-cancer, anti-inflammatory, immune-restoring, detox or regenerative claims describe the treatment or mitigation of disease and are unapproved drug claims when made for a supplement, cosmetic or biologic.

    Source: FDCA 201(g)(1); 21 CFR 101.93(g); FTC Health Products Compliance Guidance

    Safer wording: Remove anticancer, anti-inflammatory and regenerative claims. Do not describe the product as acting on disease processes.

    21 CFR 101.93(g) · Needs counsel review

  5. CG-RFA-008 · Blocks approval · Citation checked against stored text

    Pain, itch, swelling or symptom relief claims, sexual performance and fat-loss claims describe the effect of a drug on the body and are unapproved drug claims for a supplement, cosmetic or device.

    Source: FDCA 201(g)(1); 21 CFR 101.93(g); FTC Health Products Compliance Guidance

    Safer wording: Remove the symptom-relief, sexual performance and fat-burning claims, or move the product through drug approval.

    21 CFR 101.93(g) · Needs counsel review

  6. CG-STA-002 · Blocks approval · Citation checked against stored text

    Before-and-after material and personal results imply typical results and must be real, consented and fairly representative.

    Source: FTC Endorsement Guides, 16 CFR Part 255; FTC Act section 5

    Safer wording: Show what is typical, state the time frame and conditions, and keep written patient consent on file.

    16 CFR Part 255 · Needs counsel review

  7. CG-TRB-013 · Blocks approval · Citation checked against stored text

    Practicing without physician oversight, injectable parties, fake board certifications, unscreened donors and urgent-care claims of emergency capability misrepresent who is providing care and are barred by state medical practice laws.

    Source: State medical practice acts and corporate practice of medicine rules; state board of medicine rules on board-certification advertising; FDA 21 CFR Part 1271 donor eligibility; FTC Act section 5

    Safer wording: Disclose the licensed supervising physician, advertise only real board certifications from recognized boards, and do not offer injectables at social events.

    21 CFR Part 1271 · Needs counsel review

  8. CG-TRI-009 · Blocks approval · Citation checked against stored text

    Staging before-and-after photos with different lighting, retouching them, or showing hundreds of curated results with only a token disclaimer misrepresents the typical outcome.

    Source: FTC Endorsement Guides, 16 CFR Part 255; FTC Act section 5; state medical board rules on before-and-after photographs

    Safer wording: Use consistent lighting, angle and distance, never retouch results, and disclose the typical result and how the photos were selected.

    16 CFR Part 255 · Needs counsel review

  9. CG-LIC-002 · Blocks approval

    Injectables and lasers must be performed by, or under the supervision of, a licensed clinician. Supervision and scope rules for nurse practitioners vary by state.

    Source: state medical, nursing and cosmetology practice acts (state law, varies by state); FTC Act section 5

    Safer wording: Say who performs each treatment and their license, and follow your state's supervision rules.

    See source text · Needs counsel review

  10. CG-TRG-003 · Blocks approval

    Claiming that a service or product heals, fixes or reverses a named disease, quickly or at the root, is an unapproved disease treatment claim.

    Source: FDCA 201(g)(1); FTC Act section 5; FTC Health Products Compliance Guidance; FDA guidance on unapproved psychedelic and stem cell claims

    Safer wording: Remove cure, fix and reversal language. Describe the service and who delivers it, and do not promise a condition will resolve.

    See source text · Needs counsel review

What the checker flags

Sample wording we wrote to test these rules, run through the real engine at build time. The rule ids, reasons, sources and safer wording are the rule-set's own.

Injectable promo · actual checker output3 claims flagged

Erase wrinkles forever with our Botox special. Before and after photos inside. Results guaranteed.

  • Blocks approvalCG-STA-002Also matches CG-PLT-016

    Before-and-after material and personal results imply typical results and must be real, consented and fairly representative.

    Source. FTC Endorsement Guides, 16 CFR Part 255; FTC Act section 5

    Safer wording. Show what is typical, state the time frame and conditions, and keep written patient consent on file.

  • WarningCG-TRE-003

    Promises of a permanent fix, lifetime results, a time-boxed total cure, or results on every person make an outcome claim no practice can substantiate, and they imply the product replaces proven treatment.

    Source. FTC Act section 5 and FTC Health Products Compliance Guidance (competent and reliable scientific evidence); FTC Endorsement Guides 16 CFR Part 255; FDCA section 502(a) (false or misleading labeling)

    Safer wording. Drop timelines, permanence and universal-result language. State a typical, substantiated result with the evidence behind it and say individual results vary.

  • WarningCG-ABS-015Also matches CG-ABS-001

    A guarantee of results, including a money-back guarantee tied to results, promises an outcome nobody can promise for health products and services.

    Source. FTC Act section 5; FTC Health Products Compliance Guidance

    Safer wording. Describe what the service involves and say results vary. A refund policy may be stated without guaranteeing the result.

Stem cell claim · actual checker output2 claims flagged

Our stem cell injections cure arthritis. Only 3 spots left this week.

  • Blocks approvalCG-TRA-001Also matches CG-TRK-004, CG-DIS-001, CG-DIS-016, CG-DIS-018, CG-DIS-029, CG-PLT-013, CG-PLT-035

    Saying a product or service cures, reverses, clears or removes a named disease, or that a condition goes away or vanishes, is an unapproved drug and treatment claim that is not backed by evidence.

    Source. FDCA 201(g)(1) and 201(h); FTC Act section 5, deceptive health claims; FTC Health Products Compliance Guidance (2022)

    Safer wording. Remove the disease and cure claim. Describe what the service actually does, cite substantiation for any outcome, and never promise a condition will go away.

  • Blocks approvalCG-OFF-004Also matches CG-OFF-008

    Urgency and scarcity claims must be true, and false urgency is deceptive.

    Source. FTC Act section 5

    Safer wording. Use a real deadline and state it, or remove the urgency.

Permanent result · actual checker output1 claim flagged

Permanent fat loss with no surgery and no downtime.

  • WarningCG-RPL-004Also matches CG-TRC-003

    Telling people to stop medication or skip surgery, chemotherapy or a doctor is a safety risk, and implying doctors hide the truth is a deceptive framing.

    Source. FTC Act section 5; FTC Health Products Compliance Guidance

    Safer wording. Say the product or service is not a substitute for care from their clinician, and that they should talk to their clinician before changing any treatment.

Where it changes by state and platform

Next step

Run your med spas and aesthetic clinics copy through the checker

Paste the copy, choose the states and platforms you advertise in, and every flag shows its rule and source.