What is the Medical Advertising Act (HWG)? - Dominik von Falkenhausen discusses the forefront of "compliance marketing" for cosmetic clinics

Table of Contents

1. Introduction: The Background of Strengthening Medical Advertising Regulations

2. Basic Knowledge of HWG and Comparison with Japan's Pharmaceutical Affairs Law

3. Interview: Mr. Dominik Discusses the "Five Rules"

4. Points for Japanese Beauty Clinics to Learn

5. Conclusion: Towards "Smart Advertising" Rather Than "Less Advertising"

6. List of Reference Articles
   
   

1. Introduction: The Background of Strengthening Medical Advertising Regulations

With the development of digital advertising, cases where exaggerated promotions of cosmetic procedures spread on social media lead to patient troubles have been rapidly increasing even in Europe. In response, the German Federal Ministry of Health has strengthened monitoring of HWG violations from the end of 2023. Particularly, procedures with high invasive risks such as "regenerative medicine" and "liposuction" require pre-screening of advertisements.merkur.de

Meanwhile, in Japan, the 2023 amendment of the Pharmaceutical Affairs Law has made the removal order of "before and after photos" and the application of penalties a reality, forcing beauty clinics to adopt a marketing system that aims for "zero violations and maximum trust."

2. Basic Knowledge of HWG and Comparison with Japan's Pharmaceutical Affairs Law

2-1 Purpose of HWG

• Patient Protection: Elimination of Exaggerated Advertising and Unapproved Medical Treatments

• Public Health Maintenance: Entrusting Treatment Decisions to Doctors and Scientific Evidence

• Fair Competition: Prohibition of Excessive Discounts and Premium Representations
  
  
  

2-2 Main Articles

de.wikipedia.org

2-3 Differences with Japan's Pharmaceutical Affairs Law

3. Interview: Mr. Dominik Discusses the "Five Rules"

Dominik von Falkenhausen, representative of ScaleBeauty and with over 15 years of experience in managing advertising for cosmetic medicine, lists the following five items as concrete strategies to achieve results under HWG.

Rule 1: Truth and Transparency are Paramount

"Instead of 'permanently rejuvenate,' it should be presented with numbers like 'improve wrinkles by an average of 30% in 12 weeks,' accompanied by clinical data."merkur.de

Rule 2: Before and After Photos Must Be "Unedited" and Under "Identical Conditions"

• Written Consent from Patients

• Prohibition of Editing and Filters

• Clarification of Shooting Conditions (Lighting, Angle)
  
  
  

Rule 3: Patient Reviews Should Be "Testimonials" Only

Guarantees of cure are not allowed. Subjective expressions like "my skin became supple" or "I feel more positive" are within acceptable limits.

Rule 4: Emphasize Expertise with Educational Content

Blog and social media articles should be knowledge-providing, like "The Truth of Skin Aging Explained with Five Pieces of Evidence." Misinformation should be fact-checked by specialists.

Rule 5: CTA Should Be "Clear Guidance"

Instead of "Rejuvenate Now!" guide with "Book a Free Consultation." This maintains appeal while reducing risk.

4. Points for Japanese Beauty Clinics to Learn

1. Introduction of a Numerical Evidence Culture
   In Japan, the notion of "seems to work somehow" is prevalent, but adding statistical data can increase credibility.
   
   

2. Three-Step Regulation for Photo Utilization
   Routine ① Unedited ② Identical Conditions ③ Consent Form Storage.
   
   

3. Storytelling of Patient Experiences
   By linking with electronic medical records and quantifying QOL changes before and after surgery, transparency equivalent to HWG can be ensured.
   
   

4. Redesign of CTA
   By emphasizing "consultation reservation" over "procedure reservation," it is less likely to conflict with the Pharmaceutical Affairs Law guidelines.
   
   

5. Development of Hybrid Personnel in Legal and Marketing
   Make medical law training mandatory for advertising personnel and update them to "academic marketers."
   
   
   
   

5. Conclusion: Towards "Smart Advertising" Rather Than "Less Advertising"

What HWG indicates is not "do not advertise" but a stance of "respect the patient." Mr. Dominik's five rules can be seen as a prototype of "future-oriented marketing" that balances clinic revenue enhancement and patient protection. The Japanese cosmetic medical industry should shift to advertising design based on "transparency" and "evidence" before regulatory strengthening progresses.merkur.descalebeauty.de

List of Reference Articles

• Merkur Press Release "Explaining the Heilmittelwerbegesetz: Dominik von Falkenhausen of ScaleBeauty on Legally Secure Marketing..." 2025-06-16.merkur.de

• Wikipedia "Heilmittelwerbegesetz" Last Updated 2025-03.de.wikipedia.org

• ScaleBeauty Official Site "Legally Secure Advertising in Aesthetic Medicine - HWG Simply Explained"scalebeauty.de

Reference Article