Can an Influencer Legally Promote Botox, Fillers and Other Cosmetic Procedures in Denmark?

Short answer

No — not for Botox. Botulinum toxin (sold under brand names including Botox, Azzalure, Bocouture and Vistabel) is prescription-only medicine in Denmark, and advertising prescription medicine to the public is completely banned there — the same rule this Academy has already documented in detail for Ozempic and Wegovy. Hyaluronic-acid dermal fillers, by contrast, are not medicine at all — they're typically classified as the highest-risk category of medical device under the EU's Medical Device Regulation (MDR), where advertising is allowed but must be balanced, documented and not misleading. Both treatments may only be performed by a practitioner registered with the Danish Patient Safety Authority (Styrelsen for Patientsikkerhed), and a minimum two-day reflection period between consultation and treatment applies by law.

Two very different products, two very different rulebooks

"Cosmetic procedure" covers at least two product categories that are regulated in completely different ways — and confusing the two is the single most common source of error in this space:

• Botox and other botulinum toxin products (Botox, Azzalure, Bocouture, Vistabel) are a prescription-only medicine, regulated by the Danish Medicines Agency (Lægemiddelstyrelsen) under the same advertising order that bans advertising Ozempic and Wegovy.
• Hyaluronic-acid dermal fillers are not medicine at all — they're a medical device under the EU's Medical Device Regulation (2017/745, "MDR"), specifically Annex XVI, Section 3, a category that covers products with no medical purpose at all but a risk profile serious enough to still require CE marking and Notified Body oversight.

In practice, that means a brand or clinic running a campaign that touches both products at once is navigating two rulebooks simultaneously — and an influencer who shows both treatments in the same post can be under a total ban for one half of the content and a far more permissive regime for the other.

Botox: the same total ban as any other prescription medicine

Botox is classified as prescription-only medicine in Denmark, and treatment may, per the Danish Medicines Agency, only be carried out by doctors or nurses with the relevant training, under medical responsibility. That means Botox falls under exactly the same total ban on advertising prescription medicine to the public that this Academy has already documented in depth for Ozempic and Wegovy: the advertising order's § 10, stk. 1, nr. 7 specifically bans using a person of "special esteem" — a category the Danish Medicines Agency's own guidance explicitly names influencers and bloggers as an example of — in a medicine advertisement aimed at the public.

See can an influencer legally promote weight-loss drugs like Ozempic or Wegovy in Denmark? for the full breakdown of that rule, the Damgaard case (C-421/07), and how the line between a personal account and an advertisement is actually assessed — that analysis carries over word for word to Botox, because both are prescription medicines governed by the same executive order. In practice: an influencer campaign that names "Botox" or "botulinum toxin" and recommends the product to the public is banned, regardless of payment, and regardless of how carefully it's worded.

Fillers: the highest medical-device risk class — advertising is allowed, but must be documented

Hyaluronic-acid dermal fillers aren't medicine — they're classified as a medical device under the EU's Medical Device Regulation (Regulation 2017/745, "MDR"), Annex XVI, Section 3, which covers products intended for facial or other dermal or mucous-membrane filling by subcutaneous, submucous or intradermal injection. Because the injection itself carries a risk independent of any medical purpose, the MDR places hyaluronic-acid fillers in Class III — the highest risk class in the entire regulation — which requires CE marking and Notified Body assessment before the product can be sold in the EU.

That makes the rules for fillers materially less restrictive than for Botox on one central point: there is no total ban on advertising fillers to the public. See advertising medical devices through influencers: what's different from the pharma rules for the full picture of what the MDR requires of a medical-device advertisement — in short, claims must be balanced, documented and not misleading, and unusually, the marketing itself can help decide whether a product counts as a medical device in the first place.

Who may perform the treatment — and the mandatory reflection period

Regardless of whether the treatment is Botox or fillers, a separate rule applies that has nothing to do with advertising and everything to do with the clinic and the practitioner: the Danish Patient Safety Authority requires that cosmetic treatments such as lip fillers, Botox and chemical skin peeling may, as a starting point, only be performed by specially trained doctors — nurses and dentists may assist under specific conditions — and that the practitioner and clinic are registered with the authority. It is a punishable offence to perform a cosmetic treatment without that registration.

On top of that, a mandatory reflection period applies: at least two days must pass between the consultation and the treatment for lip fillers, Botox and peeling specifically — a rule the authority actively enforces through its "Fillers uden filter" ("Fillers Without a Filter") campaign. For Botox specifically, a related rule confirms that at least 48 hours must pass between a prior medical examination and the botulinum toxin treatment itself, and that cosmetic Botox treatment generally requires the patient to be at least 18 years old.

This registration and reflection-period rule is independent of the advertising rules above — it governs the clinic and the practitioner, not what an influencer may say about the treatment. But it matters for an influencer campaign for a different reason: an unregistered clinic makes any partnership problematic, no matter how compliant the advertising itself otherwise is.

What this means for an influencer in practice

The most common grey area is the difference between an influencer showing or mentioning their own treatment and the influencer actively advertising a specific clinic or product for payment. The same distinction this Academy has already set out for Ozempic and Wegovy applies to Botox: a single, neutral mention of one's own treatment with no call to purchase sits closer to a grey area than a direct advertisement, while a recommendation, a link to a clinic, or repeated positive mentions pull the post toward the advertising definition — regardless of whether the influencer is paid.

For fillers, the picture is different, because there is no total ban: the risk instead centres on whether the claims in the post are documented and not misleading (how long the effect lasts, the expected result, the risk of side effects) and on whether the clinic behind the treatment is actually registered with the Danish Patient Safety Authority. A paid partnership with an unregistered clinic is a problem regardless of whether the advertising for the filler product itself is otherwise lawful.

Decision framework

IF the content names Botox, Azzalure, Bocouture, Vistabel or "botulinum toxin" and recommends the product to the public → banned, regardless of payment.

IF the content promotes a clinic or a filler treatment → allowed, but only if the clinic is registered with the Danish Patient Safety Authority and every claim about effect and risk is documented and not misleading.

IF the influencer simply shows their own treatment unprompted and unpaid → lower risk on the Botox side, but avoid purchase-encouraging language and tags to the clinic or manufacturer; for fillers, no equivalent restriction applies, but the ordinary ad-disclosure rules still apply wherever a commercial benefit is involved.

IF the clinic or practitioner is not registered with the Danish Patient Safety Authority → the entire partnership is a problem, regardless of which of the two products the campaign is about.

Botox vs. fillers, compared

Make Influence's operational perspective

Our clear recommendation is to treat any cosmetic-procedure campaign as two separate approvals, not one: the advertising question (can the product be advertised at all, and how) and the clinic question (is the practitioner and clinic registered, and is the reflection period actually respected). In our experience, it's exactly the blending of the two that causes problems — a brand that has correctly worked out that fillers can be advertised often forgets to check whether the clinic behind them is registered, or wrongly assumes the same permissive rule applies to Botox. We never recommend naming Botox or botulinum toxin in paid influencer content aimed at Danish consumers, no matter how carefully it's worded, and we always recommend getting a clinic's registration status confirmed in writing before a filler campaign goes live. See also the brand safety checklist for influencer partnerships for where this kind of risk belongs in an ordinary approval process.

FAQ

Can an influencer show that they've had Botox at all?

It depends on purpose and form, exactly as with Ozempic and Wegovy: a single, neutral mention with no call to purchase sits closer to a grey area, while a recommendation, a link to a clinic, or repeated positive mentions pull the post toward the advertising definition — regardless of payment.

Is a paid partnership with a filler clinic allowed?

Yes — unlike Botox, there is no total ban. But the partnership requires the clinic to be registered with the Danish Patient Safety Authority, and every claim in the content must be documented and not misleading.

Does the two-day reflection period apply even if the influencer is the customer?

Yes. The rule protects every patient, whether or not they're an influencer, and applies independently of whether the treatment is later discussed commercially.

What's the penalty for illegally advertising Botox as a prescription medicine?

The same penalty range as for any other prescription medicine: a fine or up to 4 months' imprisonment under the Danish Medicines Act's rules on unlawful advertising, per ENLI's own guide to the advertising code.

How does this article differ from the article on Ozempic and Wegovy?

That article covers a single prescription medicine (semaglutide) and its specific cases. This article covers two products with two different classifications — a medicine (Botox) and a medical device (fillers) — and shows why they end up under very different advertising rules despite often being sold side by side at the same clinic.

How does this article differ from the general regulated-industries article?

The general article covers alcohol, finance and pharma as broad categories. This article goes one level deeper on cosmetic procedures specifically, including the practical patient-safety layer (registration and the reflection period) that the general article doesn't touch. See influencer marketing in regulated industries: alcohol, finance and pharma in Denmark for the broad overview.

What if a clinic asks an influencer not to name "Botox" but call it a "wrinkle treatment" instead?

That follows the same pattern this Academy has already documented for weight-loss clinics and Ozempic/Wegovy: a Danish health-law expert has publicly stated that the stricter requirements for medicine advertising aren't avoided simply by not naming the product, if the content otherwise clearly recommends the underlying prescription treatment.

Does the same classification maze apply to CBD products?

Yes, in a related but distinct way. Botox and fillers each fall neatly into one of two categories (medicine or medical device). A CBD product instead has to be checked against three possible categories at once — food, cosmetic or medicine — because its legal status depends heavily on how it's formulated and presented. See is CBD a food, a medicine or a cosmetic? What Danish law means for an influencer promoting it for that separate classification.