Dermatology claims compliance: what you can say about medical and cosmetic results, and how to show them
Every dermatology claim has to pass four tests: is it true and backed by evidence (the FTC), does it follow your state medical board's advertising rules, does it describe drugs, devices and skincare products the way the FDA classifies them, and will Google and Meta accept it in an ad. Most problems come from a handful of phrases ("cure", "permanent", "guaranteed", "FDA approved", "dermatologist" used loosely) and from before-and-after photos that aren't typical, comparable or authorized. This guide covers the dermatology-specific claims; the photo release mechanics are in our separate before-and-after photo guide.
- The FTC requires health claims to be backed by competent and reliable scientific evidence, and results shown in testimonials are likely to be read as typical.
- State boards add rules. Texas, for example, treats offering a permanent cure for an incurable disease and failing to identify models or actors as misleading.
- California requires before-and-after photos to state the procedures performed, be comparable in presentation and say that results may not occur for all patients.
- Use FDA wording precisely: drugs are approved, many lasers and devices are cleared, and a skincare product making treatment claims may be regulated as a drug.
- Meta allows cosmetic before-and-after images for adults 18+, but not copy that attacks someone's appearance or implies knowledge of a health condition.
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Four layers every dermatology claim has to pass
Short answer: federal truth-in-advertising law, your state medical board, FDA product classifications and platform policies all apply at once. Write to the strictest one that applies to the channel.
| Layer | What it governs | Dermatology examples |
|---|---|---|
| FTC | Truthful, non-misleading advertising; evidence for health claims; endorsements, testimonials and reviews | "Clears acne in 30 days", patient testimonials, influencer posts, results photos |
| State medical board | Physician and practice advertising, titles, credentials, supervision, testimonials, fees | "Board-certified", "dermatologist" for a non-physician, med spa supervision disclosures, before-and-after rules |
| FDA | How drugs, devices and cosmetics are classified and described; off-label promotion by manufacturers | "FDA approved" vs "FDA cleared", skincare drug claims, off-label injectable uses |
| Platforms | What Google and Meta will run | Prescription drug terms, health targeting, personal attributes, negative self-perception |
If your practice is a HIPAA covered entity, a fifth layer covers patient images and stories: using them in marketing generally needs the patient's written authorization. That, and the release form itself, is covered in our before-and-after photo compliance guide.
Medical dermatology claims
Short answer: describe what you diagnose and treat, and what treatment usually achieves. Don't promise cures for chronic conditions, timelines you can't guarantee or outcomes from specific drugs.
The FTC's Health Products Compliance Guidance says health-related claims must be backed by competent and reliable scientific evidence, and that the evidence must match the claim. A practice saying "our acne program clears skin in 30 days" is making an efficacy claim that needs support. A practice saying "we build an acne plan around your skin type and follow up every six to eight weeks" is describing a process.
Safer
"We diagnose and treat eczema in children and adults." "Psoriasis treatment options range from topical therapy to phototherapy and advanced systemic treatments." "Most patients see improvement over several months; we adjust the plan at each visit."
Risky
"Cure your psoriasis." "Clear skin guaranteed." "Permanent acne removal." "The most advanced eczema treatment in [city]." "Stop hair loss for good."
Prescription products
Talk about treatment types, not drug brands, in ads. On organic pages, describe approved uses accurately and avoid implying that an off-label use is approved.
Chronic conditions need extra care. Texas's medical board rules (22 Tex. Admin. Code 164.3) list "offering a permanent cure for an incurable disease, sickness, or illness" among practices deemed false, deceptive or misleading. Eczema and psoriasis are usually managed, not cured. For skin cancer claims, avoid fear-led messages and overstated screening benefits; our skin cancer screening marketing guide covers this, including the FTC's 2015 action against marketers of melanoma detection apps.
Cosmetic dermatology claims
Short answer: be honest about how long results last, how many sessions are typical, downtime, discomfort and who performs the treatment.
- Duration: "results usually last a few months" for neurotoxin, not "lasting results". Never call temporary fillers permanent.
- Sessions: laser hair removal, resurfacing and pigment treatments usually need a series. Say so on the page and in pricing.
- Pain and downtime: "most patients describe it as..." with a description of typical recovery, not "painless" or "no downtime".
- Skin of color: if you claim expertise treating darker skin types (for example with laser settings chosen to reduce pigment risk), make sure your providers, devices and outcomes support it, and show authorized photos across skin types.
- Comparisons: "better than" or "the most natural results" claims need proof. Our own style rule is to avoid superlatives entirely.
- Prices: advertised prices and specials must be honored and complete. Texas treats untruthful or deceptive claims about costs and fees as misleading advertising.
FDA wording: approved, cleared and cosmetic
- Drugs (including neurotoxins and prescription topicals) are FDA approved for specific indications.
- Devices: FDA explains that high-risk Class III devices generally need premarket approval, while many moderate-risk Class II devices are marketed after 510(k) clearance. Many aesthetic lasers and energy devices are cleared, not approved. Write "FDA-cleared for [indication]" and check the actual clearance.
- Skincare you sell: FDA says intended use, shown by the claims made, decides whether a product is a cosmetic or a drug. "Improves the look of fine lines" is a cosmetic claim; "treats rosacea" or "stimulates collagen production" can make it a drug claim.
- Off-label uses: physicians may use approved products off-label, but marketing should not imply FDA approval for those uses. See our off-label injectable advertising guide.
Credentials, titles and supervision
Short answer: say exactly who treats the patient and what their license and certification are. Credential confusion is one of the most common dermatology advertising problems.
- "Board-certified dermatologist" only for physicians certified by a recognized board in dermatology, such as the American Board of Dermatology. Texas explicitly prohibits "board eligible" or "board qualified" wording that suggests certification.
- Non-physician clinicians: describe PAs, NPs, RNs and estheticians by their actual title. Don't let page headings ("Meet our dermatologists") sweep them in.
- Supervision: where state rules require it, disclose physician supervision or delegation. Texas requires disclosure of medical directorship, supervision or delegation to non-physicians at non-primary practice locations.
- Fellowships and memberships: "FAAD" (Fellow of the American Academy of Dermatology), Mohs fellowship training and society memberships are meaningful; state them precisely.
State-specific rules are summarized in our state medical board advertising guide and in individual guides for Texas, California and Florida.
Before-and-after photos in dermatology: the claims side
Short answer: a results photo is a claim. It has to be genuine, unaltered, comparable, representative and authorized, and it should say what was done.
Dermatology photos are especially easy to get wrong because small changes in lighting, makeup and angle can make acne, pigment and texture look dramatically better. Treat every photo as you would a written efficacy claim.
- Typical results. The FTC Endorsement Guides (16 CFR 255.2) say an endorsement conveying results is likely to be read as representing what people can generally expect. If the result isn't typical, clearly disclose what is.
- State the procedure. California Business and Professions Code 651 treats before-and-after views as misleading unless they specify, prominently, what procedures were performed.
- Comparable presentation. California also requires before and after views to be comparable so results aren't distorted by poses or lighting, with a statement that the same results may not occur for all patients. It prohibits images altered from the actual subject.
- Models. Texas requires models or actors to be identified as such rather than presented as actual patients.
- Timing and combinations. Say how long after treatment the photo was taken and whether multiple treatments or a skincare regimen were involved. Acne photos after months of combined therapy shouldn't be captioned as a single treatment.
- No editing of the treated area, no filters, no skin smoothing.
- Authorization. Written patient authorization for marketing use, including where the image will appear.
The release form, consent types and reuse on Instagram, TikTok and YouTube are covered in depth in our before-and-after photo compliance guide; we won't repeat them here.
Google and Meta rules for dermatology claims
- Google Ads: restricts prescription drug terms in US ads, keywords and landing pages; prohibits ads for speculative and experimental medical treatments; and treats health as a sensitive category for personalized advertising. Details in our dermatology Google Ads guide.
- Meta, cosmetic procedures: Meta's health and wellness policy requires ads for cosmetic products, procedures and surgeries to target people 18 and older, and permits before-and-after images for general cosmetic procedures within that targeting. Its list of cosmetic procedures includes dermal fillers, injectable treatments, chemical peels, microneedling and non-ablative laser treatments.
- Meta, negative self-perception: ads can't contain statements of inferiority about physical appearance. "Embarrassed by your acne scars?" fails; "Acne scar treatment options from a board-certified dermatologist" works.
- Meta, personal attributes: ads can't assert or imply knowledge of a person's medical condition. Avoid "your eczema", "your psoriasis" or "do you suffer from...".
- Prescription drugs on Meta: promotion is limited to authorized advertisers. Keep ads about the practice and the treatment, not the drug.
Testimonials, reviews and influencers
- Reviews: the FTC's rule on consumer reviews and testimonials (16 CFR Part 465, effective October 21, 2024) bans fake reviews, conditional incentives for positive reviews, undisclosed insider reviews and certain review suppression. See our dermatology reviews and reputation guide.
- Influencers and staff: anyone who gets free or discounted treatment, payment or another material connection must disclose it clearly. Our influencer endorsement guide covers the details.
- State testimonial rules: Texas, for example, requires certain disclosures about a testimonial giver's credentials and compensation.
A pre-publish checklist
- Can we prove this claim with evidence that matches it?
- Does it promise a cure, permanence, a guarantee or a timeline?
- Are credentials and titles exact for every clinician named or pictured?
- Are FDA terms (approved, cleared) accurate for this product and indication?
- Are photos authorized, unedited, comparable, labeled with the procedure and representative?
- Does the ad version avoid drug brand names, appearance attacks and implied knowledge of a condition?
- Does it meet our state board's specific rules?
Ichelon Consulting US runs claims checks on dermatology content and ads as part of our dermatology marketing and dermatology services, including cosmetic dermatology marketing, with city pages such as Los Angeles and Scottsdale. Market context is in dermatology marketing statistics 2026, the dermatology Google benchmarks and the US dermatology marketing benchmark report. Comparing agencies? Read dermatology marketing agencies in the US. More in the US guides library.
Sources
- FTC: Health Products Compliance Guidance
- 16 CFR Part 255: FTC Endorsement Guides (including 255.2, generally expected performance)
- 16 CFR Part 465: Use of consumer reviews and testimonials
- 22 Tex. Admin. Code 164.3: Prohibited acts or omissions in advertising
- California Business and Professions Code 651 (before-and-after images)
- FDA: Is it really "FDA approved"? (approval vs 510(k) clearance)
- FDA: Is it a cosmetic, a drug, or both?
- Meta Advertising Standards: Health and wellness
- Meta Advertising Standards: Privacy violations and personal attributes
- Google Ads policy: Healthcare and medicines
- 45 CFR 164.508: HIPAA authorization for marketing
- American Board of Dermatology
Note: general marketing information, not legal advice. Rules vary by state and change; have counsel review claims, photos and offers before publishing.
Related pages from the US team
Before-and-after photo compliance guide
Release forms, consent types and social reuse in full.
State medical board advertising rules
How US boards regulate healthcare advertising.
Cosmetic dermatology marketing
Our cash-pay dermatology service.
Dermatology Google Ads guide
Prescription drug terms and other ad policy limits.
Dermatology reviews and reputation
Testimonial and review rules in practice.
Dermatology marketing agencies compared
Ask agencies how they review claims.
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Common questions
Can a dermatology practice say it "cures" acne, eczema or psoriasis?
Avoid it. Eczema and psoriasis are chronic conditions that are managed rather than cured, and Texas's medical board rules, for example, treat offering a permanent cure for an incurable disease as misleading advertising. Say what you do: diagnose, treat, control flares and help patients reach clearer skin, with realistic language about what treatment typically achieves.
Is it OK to say a laser is "FDA approved"?
Only if it is. FDA uses "approved" for drugs and for high-risk devices that go through premarket approval. Many aesthetic lasers and energy devices reach the market through 510(k) clearance, so "FDA-cleared for [the cleared indication]" is the accurate phrase. Check the device's actual clearance and indication before writing the claim.
Do before-and-after photos need a disclaimer?
Often. Under the FTC Endorsement Guides, results shown are likely to be read as what people can generally expect, so atypical results need a clear statement of typical results. California requires a statement that the same results may not occur for all patients and that the procedures performed be specified. Check your own state's rules.
Can a physician assistant or nurse practitioner be called a dermatology provider?
Describe each clinician by their actual license and role, such as "board-certified physician assistant specializing in dermatology" where accurate. Avoid wording that implies a non-physician is a dermatologist or a physician, and follow your state's rules on titles and on disclosing supervision.
Can we say "board-certified dermatologist"?
Yes, for physicians who hold current certification from a recognized board such as the American Board of Dermatology or the American Osteopathic Board of Dermatology. Don't use "board eligible" or similar wording as if it meant certified; Texas specifically prohibits that.
Can we market the skincare products we sell in the office?
Yes, but the claims determine how the product is regulated. FDA says a product's intended use, shown by its claims, decides whether it is a cosmetic or a drug. A moisturizer that "improves the look of dry skin" is a cosmetic claim; one that "treats eczema" is a drug claim.
A note on this guide: it explains marketing practice, not legal advice. Rules on privacy, advertising and insurance change and vary by state, so confirm anything compliance-related with your own counsel.
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