These changes, while not legislative amendments, stem from a clarification of existing laws under the Medicines and Poisons Act 2019 (MPA) and Medicines and Poisons (Medicines) Regulation 2021 (MPMR). The intention? To eliminate confusion, safeguard public safety, and ensure prescribing, dispensing, and administering medications occurs within lawful bounds.
🗾️ No New Laws—But a New Interpretation That Matters
Queensland Health confirms there have been no changes to the existing legislation. However, during compliance activities, they identified widespread misunderstandings, prompting the release of updated guidance and a revised fact sheet in April 2025.
This clarification caused a wave of concern, especially among nurse-led clinics, with fears that many were unknowingly operating outside legal parameters. While Queensland Health maintains the laws haven’t changed, the interpretation of what constitutes “compliant” conduct has been sharpened.
👩⚕️ The Role of Nurses and Prescribers: What’s Allowed Now?
At the heart of the issue is how S4 medications like anti-wrinkle injectables and dermal fillers are prescribed, obtained, and stored.
Key takeaways:
Registered Nurses (RNs) cannot purchase or stockpile S4 medicines at their clinics.
Only dispensed medicines, labeled specifically for an individual patient, may be held by RNs for administration.
Prescribers (Doctors or Nurse Practitioners) must have exclusive custody and control over the medicine if they purchase it—meaning they must practice from the location.
Telehealth prescribing remains lawful, but medications must still be dispensed correctly, and only administered with proper labels and documentation.
“We don’t think it would be wise to harm an industry deliberately when there is no evidence of patient safety concerns,” said Dr. John Delaney, co-founder of one of Australia’s leading cosmetic telehealth companies.
🛆 Dispensing, Delivery & Storage – The New Gold Standard
Queensland clinics can no longer rely on outdated systems of consignment or shared stock. Instead:
Medicines must be dispensed by a pharmacist or doctor and labeled per the Poisons Standard.
They must be assigned to a specific patient and not held as stock for general use.
RNs can only hold medicine if it is dispensed and labeled for a particular client.
Additionally, administrative staff are prohibited from ordering or receiving medicine stock. All medicine movement must follow strict legal chains of responsibility.
🏥 The Controversy and Industry Backlash
The December 2024 publication created panic, with suggestions that nurse-led injectables clinics were operating illegally. The updated April 2025 factsheet seeks to calm the storm but reinforces that compliance is not optional.
Since the announcement, petitions from nurses and crisis meetings have led Queensland Health to acknowledge that most non-compliance cases are not deliberate, promising to work closely with the sector to improve education and adherence.
“Cosmetic injectable treatments are prescription-only substances that can cause serious harm if used improperly,” said a Queensland Health spokesperson. “That is why we are working with staff from the industry to ensure they meet their obligations under the current legislation.”
🔍 The Broader Impact: What Clinics Must Do Now
Review Your Current ModelEnsure your prescriber has physical oversight or that all medications are dispensed with individual labels.
Stop Holding Bulk StockIf you’re storing general S4 medicines on-site—stop. You must only possess patient-specific dispensed medicine.
Update SOPs and Staff TrainingTrain all staff, especially administrative teams, on who is legally permitted to handle medicine orders and possession.
Engage With Prescribers CarefullyYour prescriber must practice from the location if they’re responsible for medicine stock—or ensure dispensing is handled via pharmacy protocols.
Stay Connected to the ConversationQueensland Health will continue industry consultations and release further updates. Clinics should remain engaged and prepared to adapt.
⚖️ A Call for National Clarity
This isn’t just a Queensland issue. As demand for cosmetic injectables continues to rise, a consistent national approach is urgently needed. Differences in legislation across states create confusion and risk for providers and patients alike.
The upcoming Medical Board of Australia guidelines, expected to be released soon, may offer more national direction.
🧠 Final Thoughts: Safety, Not Shutdowns
The industry must shift from reactive to proactive. These new interpretations aren’t designed to shut clinics down—but to set a clearer standard for safe, ethical, and legal practice. Those who embrace the reforms will be better positioned for long-term sustainability and trust.
“Clarity creates confidence. This is an opportunity to elevate the standards and future-proof your business.” – Nicole Montgomery, Founder, Aesthetic Business Masters
📩 Need More Support?
Contact Queensland Health’s Medicines Approvals and Regulation Unit (MARU):📧 MARU@health.qld.gov.au
