Melissa Crozier, Marketing Manager

Role: Marketing Manager — a non-clinical role

Registration: Not applicable. Marketing is not a registered health profession. The Dental Board of Australia does not register marketing or administrative staff, and no AHPRA registration attaches to this role.

The practice publishes no further biographical detail for this position. The full team list is on the our team page, and the clinicians' registrations are set out on the dentists and registered specialists page.

A marketing title is not a clinical qualification. Only a registered practitioner may diagnose, recommend treatment, or explain clinical risk.

Advertising a regulated health service in Australia

Marketing in healthcare is not like marketing anything else, and the difference is legal rather than stylistic. Section 133 of the Health Practitioner Regulation National Law governs how any regulated health service may be advertised, and it binds anyone who advertises such a service — practitioners, practices, and non-practitioner businesses alike.

Breaches carry real consequences: AHPRA can and does prosecute, and a practitioner can face disciplinary action for advertising placed by someone else on their behalf.

What is prohibited

1. Testimonials about clinical care. This is the provision most often broken and most often misunderstood. Advertising a regulated health service may not use testimonials or purported testimonials about the clinical aspects of the service. That covers reviews about treatment, outcomes, skill or results — whether they appear on the practice's own website, in an advertisement, or in social media the practice controls.

What it does not cover: reviews that patients post independently on platforms the practice does not control, such as Google or a review site, provided the practice does not solicit, curate or reproduce them in its own advertising. Comments about non-clinical matters — parking, the friendliness of reception, the wait time — are outside the definition. The practice's own reviews page is written against that boundary.

The rationale is that a patient cannot evaluate whether a clinical outcome was good, and testimonials cannot be verified or contextualised. It is not a comment on the honesty of the people writing them.

Ahpra's guidelines treat the responsibility question as separable from the content question: the published examples "help to explain who is responsible for ensuring compliance with the advertising requirements of the National Law in relation to reviews from the public", and "where the review appears and whether it is being used in advertising (as defined in these guidelines) are important for determining who is responsible". In other words, the same words can be compliant in one place and a breach in another, depending on who put them there.

2. Misleading or deceptive advertising, including by omission. A price that omits an unavoidable additional cost is misleading — which is why the price guide states what a figure does and does not include, and understanding your treatment describes the written plan that follows.

3. Claims that create an unreasonable expectation of benefit. "Permanent", "guaranteed", "pain-free", "life-changing", and implied promises of a particular result.

4. Offers of gifts, discounts or inducements without the terms and conditions clearly stated — and time-limited offers that pressure a patient into an irreversible clinical decision attract particular scrutiny.

5. Advertising that encourages the indiscriminate or unnecessary use of a health service. "Two-for-one" style promotions on clinical treatment fall here.

6. Claims of superiority. "Best", "leading", "number one", "the only practitioner who" — anything asserting superiority over other practitioners, unless it can be substantiated with acceptable evidence, which in practice it rarely can. Where the practice records an award, the awards and media pages attribute and date it rather than restating it as a claim.

7. Advertising prescription-only medicines to the public. Under the Therapeutic Goods Act, Schedule 4 medicines cannot be named, branded, priced or promoted in public-facing material. This is why cosmetic injectable treatments relying on prescription medicines are described only in general terms, never by product name. The restriction applies regardless of who provides the treatment.

8. Misuse of protected titles. Specialist titles — orthodontist, periodontist, endodontist, prosthodontist, paediatric dentist, oral and maxillofacial surgeon and the rest of the thirteen recognised specialties — may only be used by practitioners holding specialist registration. Implying specialty through phrasing such as "specialising in" or "specialist services" where no specialist registration is held is a breach. Why would I need to see a dental specialist? and finding a dentist online in Australia explain what the title actually signals, and specialist orthodontist vs general dentist: which is best for Invisalign? works through one common case.

‘Acceptable evidence’ — the standard a claim actually has to meet

The phrase does a great deal of work in these rules, and it is narrower than most marketing departments assume. Ahpra's guidelines state that "advertisers of a regulated health service must be able to substantiate claims made in advertising", and that acceptable evidence "mostly includes empirical data from formal research or systematic studies in the form of peer-reviewed publications". A practitioner's own clinical experience, a supplier's brochure or a plausible mechanism is not that.

The guidelines also draw a distinction that explains why the bar sits where it does. "The evidence required for claims in advertising and the evidence for clinical decisions about the services provided are different." In the surgery, informed consent means patients "have an opportunity to consider a proposed treatment, benefits and potential negative effects, ask questions of their practitioner(s) and make informed decisions". Advertising gives no such opportunity — "the claims are generic and practitioners are not available to clarify whether a treatment is appropriate for an individual". (Source: Ahpra, Guidelines for advertising a regulated health service.)

That is the whole logic of the regime in two sentences: a conversation can be qualified, and an advertisement cannot.

What the penalties are

Advertising breaches are not a matter of a stern letter. "A breach of an advertising requirement is a criminal offence for which a court may impose a monetary penalty", and Ahpra's powers "include the power to prosecute which may lead to a financial penalty".

The amounts changed, and both figures appear in current material, so it is worth stating which period each belongs to. The guidelines as originally published set penalties for an advertising offence at up to $5,000 per offence for an individual and $10,000 for a body corporate. "In 2022, the National Law was amended" to increase them: "for an individual, the maximum financial penalty per offence increased from $5,000 to $60,000, and for a body corporate the maximum financial penalty per offence increased from $10,000 to $120,000", and "as of July 2024 these increased penalties now apply in all jurisdictions, including Western Australia".

Unlawful use of a protected title is treated more seriously again. For an individual there may be "a financial penalty of up to $60,000 per offence, imprisonment of up to three years per offence or both"; for a body corporate, "a financial penalty of up to $120,000 per offence may apply". Western Australia has historically applied different figures for that offence — "in the case of an individual the maximum penalty is $30,000, or in the case of a body corporate $60,000". (Source: Ahpra, Guidelines for advertising a regulated health service; Increased maximum penalty for advertising offences.)

The practical reading for a patient is simple. When a dental website calls someone a specialist, that is not a marketing flourish — it is a statement with a custodial sentence attached to getting it wrong, and it can be checked for free on the register in under a minute.

Before-and-after images

Permitted, and tightly conditioned — the practice's own set is on the before and after gallery. Images must:

A related point: a rendered or photographed proposal is not a prediction either, which is why a trial in the mouth — the mock-up reveal — tells a patient more than any image does.

Cosmetic procedures

Additional guidelines apply to advertising cosmetic procedures, covering the use of images, restrictions on advertising to people under 18, and requirements around cooling-off periods and consent. Practices offering cosmetic treatment carry a higher compliance burden, not a lower one. The consequences of ignoring all of this are set out plainly in Turkey Teeth: the real risks of getting veneers overseas and what are the risks of having dental treatment overseas?

One dental example of the overlap is worth naming, because it is where advertising law, poisons law and scope of practice meet. The Dental Board states that "Australian laws mean only registered dental practitioners can use or supply high-concentration teeth whitening products (over 18% carbamide peroxide or 6% hydrogen peroxide)", and that advertising such products must comply with the National Law requirements, the advertising guidelines, "State and Territory restrictions on advertising controlled substances" and "TGA regulations for advertising" simultaneously. (Source: Dental Board of Australia, Teeth whitening products.) See teeth whitening.

Why this exists, and why it is worth defending

The underlying principle is that a patient cannot assess the quality of a health service the way they can assess a restaurant. They lack the clinical knowledge, the outcome may not be apparent for years, and the decision is often irreversible. Ordinary consumer signals — reviews, testimonials, comparative claims, promotional urgency — mislead in this context in a way they do not when buying a toaster.

So the law removes those signals and substitutes others: the public register, the protected titles, the itemised written plan, and the right to a second opinion.

What a patient can actually rely on:

  1. The AHPRA public register at ahpra.gov.au — free, searchable by name, showing registration category, specialty held and any conditions on practice. The Dental Board confirms that Ahpra "publishes an online register of all dental practitioners" which "also includes details of the specialty or specialties for dentists who hold specialist registration".
  2. A written, itemised treatment plan with item numbers, before anything starts.
  3. A stated alternative, including the least expensive reasonable option and doing nothing.
  4. The right to take it away, think, and get a second opinion — which no reputable practitioner objects to.
  5. Time. Elective dental treatment is almost never urgent. Feeling rushed is a reason to pause, not to proceed. 5 questions you've always wanted to ask your dentist and what makes a truly great dentist? are better starting points than any advertisement.

Where to raise a concern

Common questions

I want to write a review about my treatment. Am I allowed to?

Yes. The restriction in section 133 falls on the advertiser, not on you. You are free to write whatever you honestly think, wherever you like.

Where it gets complicated is what a practice may then do with it. Ahpra's own framing is that "where the review appears and whether it is being used in advertising (as defined in these guidelines) are important for determining who is responsible". A review you post on an independent platform of your own accord is yours. The same words lifted onto a practice website, quoted in an advertisement, or reposted on a channel the practice controls become that practice's advertising — and if they describe clinical care, outcome or skill, they are a testimonial and are prohibited.

That is why practices that follow the rules look oddly quiet: they are not allowed to show you the thing you most want to see. It also means you should read an Australian dental site's silence on outcomes as compliance rather than as a lack of satisfied patients — and, conversely, treat a dental site that is full of glowing clinical testimonials as having told you something about how carefully it reads the rules.

If you want to raise something directly rather than publicly, the routes are listed above.

An offer says ‘complimentary consultation’ or gives a discount. Is that lawful?

It can be, and there is one test that settles most of it: the terms have to be there. Section 133 prohibits advertising that "offers a gift, discount or other inducement to attract a person to use the service or business, unless the advertisement also states the terms and conditions of the offer". An offer with its conditions stated is permitted; a bare offer is not.

So when you see one, look for what is missing. What exactly is included in the complimentary appointment, and what is not? Does it include radiographs, or are those charged? Is it with a named practitioner or whoever is free? Does the discount apply to the whole plan or one item? When does it end, and what happens if the treatment runs past that date?

Two further limits are worth knowing. Advertising must not "directly or indirectly encourage the indiscriminate or unnecessary use of regulated health services" — which is why bulk or two-for-one promotions on clinical treatment are a problem rather than a bargain. And a countdown on an irreversible clinical decision deserves particular suspicion: the treatment will still be clinically appropriate, or not, next month. Feeling rushed is a reason to pause.

I have been quoted a fraction of the price for veneers overseas, with a guarantee. How should I read that?

Take the guarantee first, because it is the easiest part. An Australian advertisement may not create an unreasonable expectation of benefit, and "guaranteed" is the standard example. An offshore advertisement is not bound by the National Law — so a guarantee in that setting tells you about the jurisdiction the clinic advertises in, not about the durability of the work. It is also, in practice, a promise you would have to travel back to enforce.

The substantive issue is what is actually being done to the teeth. A 2025 British Dental Journal review of UK media coverage of dental tourism records dentists' repeated observation that the treatment sold as veneers is frequently not veneers at all — one quoted practitioner puts it as: "They talk about veneers — mouldings bonded to the front of a tooth — but in reality, they are crowns, meaning much more aggressive tooth reduction." That distinction has a measured basis. Published tooth-reduction figures put a crown at roughly 63 to 72 per cent of coronal tooth structure removed against roughly 16.7 per cent for a traditional facial veneer (Edelhoff and Sorensen — anterior teeth, in vitro, on a typodont, so treat it as an order-of-magnitude comparison rather than a patient measurement).

On aftercare, the same review notes that some private providers described "actively avoiding the provision of care for people who'd had dentistry abroad because of fear of liability". The Australian Dental Association makes the equivalent point in its own policy: the potential challenge of finding a practitioner to continue with, or repair, elective treatment started overseas.

Two honest qualifications. The quantified complication figures in circulation — a British Dental Association survey of 1,000 UK dentists in 2022, in which 86 per cent reported treating people suffering consequences after treatment abroad, with remedial costs commonly above £1,000 and above £5,000 for one dentist in five — are UK self-reported survey data, not an Australian clinical audit. And the published destinations for Australian dental tourists are Indonesia and Thailand rather than Turkey; the "Turkey teeth" framing is a British pathway.

The authors of that review add something worth repeating: people making these decisions are usually working within real financial limits, and the right response to a complication afterwards is care, not scorn. See Turkey Teeth: the real risks of getting veneers overseas and what are the risks of having dental treatment overseas?

An advertisement says veneers ‘last ten to fifteen years’. Is that a real figure?

That range is widely repeated and we have not been able to trace it to any dental authority or published study. No regulator or professional body publishes a lifespan in years for a veneer, and a durability claim in Australian advertising would need "acceptable evidence" — which Ahpra defines as "empirical data from formal research or systematic studies in the form of peer-reviewed publications". A number with no source behind it does not meet that.

What the literature does publish is survival at a stated time point, which is a different and more honest kind of statement. A 2021 systematic review in the Journal of Clinical Medicine pooled 25 studies and 6,500 porcelain laminate veneers and estimated a 10-year cumulative survival rate of 95.5 per cent — counting fracture, debonding, secondary caries and loss of vitality as failures. Note what that does and does not mean: 433 of the 6,500 failed on that definition, and the review is explicit that surviving is not the same as still looking good, since some restorations were repolished or repaired along the way.

Material matters more than most advertisements admit. A 2022 head-to-head analysis (Mazzetti and colleagues, Dental Materials) found composite veneers at roughly four times the failure risk of ceramic for survival (hazard ratio 4.00, 95% CI 2.74–5.83), with annual failure rates on the stricter "success" definition of 9.1 per cent at five years and 10 per cent at ten for direct composite, against 2.9 per cent and 2.8 per cent for ceramic.

So the useful question to a clinician is not "how long will these last" but "what material, and what is the published survival at ten years for that material, and what counts as a failure in that figure?" That question has an answer. "Ten to fifteen years" does not. See porcelain veneers.

Related reading

Practical details

For media and marketing enquiries, contact the practice directly. For clinical questions, ask to speak with the treating practitioner. Call 13 13 96, or use the contact page.

Smile Solutions, Level 1, 220 Collins Street, Manchester Unity Building, Melbourne VIC 3000. Phone 13 13 96, or theteam@smilesolutions.com.au. Monday–Friday 8.00am–6.00pm, Saturday 8.30am–1.30pm, Sunday by appointment.

This page records a role as published by the practice, and a general account of Australian advertising law for regulated health services. It is not legal advice and it is not a statement about any particular practice's compliance. Penalty amounts and guideline wording change; confirm the current position with Ahpra before relying on any figure here.

Smile Solutions trades under ABN 28 193 514 103.

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