Notes · Private clinics
In Switzerland, the word your patients search for most is the one your website cannot write.
Article 32 of the Swiss Therapeutic Products Act, Swissmedic’s 2026 guidance on botulinum toxin, the fines in Article 87, where the word nobody checks is hiding, and why a high-end clinic does not need it.
Picture this: an aesthetic medicine practice opens in Geneva and launches its website. On the home page, “Botox” in large type and an introductory price. Below it, a gallery of before and after photos. At the bottom, a discount on the first session in January. The agency that designed it used the same template as for a clinic in Miami. None of those three elements survives the guidance Swissmedic updated in March.
In Switzerland, an aesthetic clinic may explain what it does. What it may not do is advertise the medicine it does it with. The difference looks small and decides almost the entire website.
What the law says.
Article 32 of the Federal Act on Medicinal Products and Medical Devices prohibits advertising to the public for medicines that may only be dispensed on prescription. Only professional advertising, aimed at those who may prescribe or dispense them, is allowed. And Article 87 punishes anyone who breaches the rules on advertising medicines with a fine of up to CHF 50,000 if they act intentionally, and up to CHF 20,000 if they act negligently.
What Swissmedic spells out.
Swissmedic’s MU105 guidance on botulinum toxin, version 2.2 in force since 1 March 2026, points out that these products sit in the strictest prescription category. Towards prospective patients, a clinic may only give general information about health or diseases in relation to the treatment. And it lists what has no place on a website promoting medical services.
Brand names such as “Botox” may not be mentioned. Before and after photos count as promises of the medicine’s effect and are not allowed on a website in any case; according to the guidance, they would not be allowed even if the product did not require a prescription. Discounts on botulinum toxin treatments are treated as serious breaches. And no unauthorised indication may be promoted. The guidance adds that the overall impression decides: citing the active ingredient prominently or in a promotional tone can already be advertising.
Swissmedic also explains where it acts. It concentrates on cases with the greatest health risk. Ads for “wrinkle filling” that do not mention the medicine, or those from beauty institutes, are passed on to the cantonal authorities.
What I do not know.
The guidance is guidance; in a dispute a court decides, case by case. I do not know how often cantonal authorities act, or whether they all apply the same standard. The guidance talks about websites; I have not found an equivalent recent guide for Instagram or search ads, although the overall-impression test does not seem to depend on the channel. Hyaluronic acid fillers are medical devices with other rules, which I do not analyse here. I am not a lawyer. What your clinic may publish is a question for your legal counsel.
The blind spot: the word is not only in the text.
A clinic checks the paragraphs on its website and thinks it is done. But the word is still in the page title Google shows, in the description, in the page address, in the image alt text, in the ad keywords, in the FAQ, in the chatbot’s answers and in the English version nobody has reread. And there is a real tension: it is what people type into the search bar. An agency that thinks only about rankings will put it everywhere.
What your patient is looking for is not a brand. It is an answer to what they see in the mirror.
Where I stand.
I believe a high-end aesthetic clinic does not need that word. Someone who can afford the best clinic does not compare brands of vials; they compare judgement: who will perform the treatment, with what training, what will be assessed beforehand, what will never be done and which risks will be explained. All of that can be written without naming a medicine, and it is exactly what a generic website does not say. A clinic that needs the brand to sell competes on price. One that does not need it competes on trust.
What I would check.
- Every mention of a brand. In text, titles, descriptions, page addresses, images and ads, in every language.
- Before and after photos. On the website, in presentations and on the profiles it links to.
- Prices and promotions. Whether any offer touches a treatment with a prescription medicine.
- Indications. Whether the website promises uses the medicine is not authorised for.
- Tone. Whether the page reads as medical information or as an advert.
Where to start.
- This week
Search for the word
In the website’s code, not only in what is visible, and in every language.
- This month
Remove what the guidance excludes
Brands, before and after photos and discounts, with your legal counsel.
- This quarter
Rewrite from the consultation
What worries the person consulting, who carries out the assessment, which options exist and what the risks are.
- Every campaign
Check before publishing
Ads, social media and automated replies go through the same list.
Search your own website, but not the way a patient would. Open the page’s code, the alt text of the images and the description Google shows, and look for the word in every language on your site.
If it is not there, a more interesting question remains. If you cannot write the word your patient is searching for, which word of yours do you want them to remember when they leave the consultation? Many clinics have no answer, and that is why they all look alike.
If you would like me to review where that word appears on your website today, in every language and in the code nobody sees, and how to describe your work without it, start with the Strategic Diagnostic. What your clinic may publish is for your legal advisers to decide, not a designer.