A dermatology clinic in Makati and a wellness brand selling a supplement face completely different rules, even when they publish the same-looking Instagram post. The difference is the claim, not the business.
That catches agencies out constantly. A general agency treats a clinic like a salon, posts about a branded serum with a result photo and a doctor on camera, and has walked into three separate regimes without noticing.
First, who the four regulators are
FDA is the Food and Drug Administration, which regulates health products under Republic Act 9711. Drugs, food and dietary supplements, medical devices and cosmetics all fall to it. It operates a pre-clearance system, meaning advertising for these products generally needs a permit before it is published rather than review afterwards.
PRC is the Professional Regulation Commission, which licenses and disciplines professionals including physicians. Alongside it sits the PMA, the Philippine Medical Association, whose Code of Ethics governs how physicians may conduct themselves commercially. Breaches are disciplinary matters attaching to the doctor personally.
ASC is the Ad Standards Council, an industry self-regulatory body that screens advertising material against its own code. It is not a government agency, but non-compliance causes practical problems because media and platforms often require clearance.
DTI is the Department of Trade and Industry, which administers the Consumer Act, Republic Act 7394. Deceptive and misleading claims fall here, as do sales promotions involving prizes, which need a permit.
The rule that catches the most people
In November 2025 the FDA issued Advisory No. 2025-1552, a public health warning about the advertising, promotion and marketing of food and dietary supplements for therapeutic purposes. It flagged supplements being promoted for unapproved indications and restated the labelling and advertising requirements.
Two of those requirements catch almost every wellness brand in the country. Supplement labels must carry the no approved therapeutic claims statement. Advertising, promotion and sponsorship of supplements must carry the Filipino version, which reads that the product is not medicine and should not be used to treat any illness. That requirement dates back to a 2015 FDA memorandum circular and is still routinely ignored on social media.
- Does every ad and sponsored post carry the mandatory Filipino statement, not just the label?
- Does any caption say the product treats, cures or prevents anything?
- Do your influencers carry the statement in their posts, or only you?
- Is the product actually registered, with a valid advertising permit?
Words and phrases to avoid
The practical list. The left column is what health and wellness copy reaches for by default. The right column keeps the meaning without making a claim you cannot defend.
| Avoid | Why | Say instead |
|---|---|---|
| Cures, treats, heals, prevents | Therapeutic claim; not permitted for supplements | Describe the ingredient and carry the mandatory statement |
| FDA approved | Registration is not approval or endorsement of a claim | FDA-registered, with the registration number if accurate |
| Best, safest, most advanced clinic | Unsubstantiated superlative | Name the equipment, or the qualification held |
| Guaranteed results, permanent, 100% effective | Outcome claim you cannot substantiate | Results vary. A typical course is four to six sessions |
| No side effects, completely safe | Unsubstantiated safety claim | State the known risks and who should avoid it |
| Clinically proven | Requires evidence you can produce on request | Cite the study, or remove the phrase |
| Miracle, breakthrough, secret formula | Misleading under consumer protection rules | Describe what the product actually does |
| Doctor recommended, as used by Dr X | PMA code bars physician commercial endorsement | Remove. A doctor may explain, not endorse |
| Instant, overnight, fastest | Implied outcome and timeline | Give the realistic timeframe |
The pattern behind every row: replace a promise with a description.
Images
Fine. Your clinic, your equipment, your staff, procedures shown neutrally, and educational diagrams. Photographs of your own practitioners with accurate captions.
Careful. Before-and-after photographs, which are not banned in the Philippines but become an unsubstantiated claim once they imply a typical or guaranteed result. If you use them, state what was done over what period and avoid presenting the outcome as standard. Any identifiable patient image needs consent under the Data Privacy Act, and consent for treatment is not consent for marketing.
Avoid. Stock photographs of models in white coats presented as though they are your practitioners. Images implying a result the product or procedure cannot reliably deliver. Anything showing a patient's records or identifiable details.
Logos, credits and accreditations
This is where wellness brands most often overstate, usually without meaning to.
Generally fine. Stating that a product is FDA-registered and giving the registration or notification number, where that is accurate. Displaying your practitioners' PRC licence details. Naming genuine hospital affiliations, fellowships and specialty board certifications. Legitimate accreditations your facility actually holds.
Avoid. Using the FDA, DOH or PhilHealth logo in promotional material, which implies an endorsement that none of them give. Describing a registered supplement as FDA approved, since registration confirms the product is registered and is not an endorsement of any health claim attached to it. Displaying accreditations that have lapsed, or that belong to a partner facility rather than to you.
Channel by channel
1. Your website and service pages
The least restricted channel you have. Describing your services, your facilities, your practitioners and your process is factual information about your own practice. Consultation fees and what a visit involves are safe and useful. The line is crossed when a page makes a therapeutic claim about a named product, or asserts an outcome you cannot substantiate.
2. Blog and SEO content
Also lightly restricted, and the most underused. Explaining a condition, what causes it, what the treatment options are and what recovery involves is education rather than advertising. This is where clinics should be spending most of their effort, because it is both permitted and matched to how patients actually search.
3. Google Business Profile and local listings
Entirely factual: name, address, hours, services, photographs. Nothing here touches restricted territory, and it is the single highest-return item for a clinic serving one city. Keep the details identical across every listing.
4. Organic social media
Fine for education and clinic life. The moment a post promotes a specific product with a health benefit attached, you are in FDA territory and may need an advertising permit before publication. The informal register of social media is exactly why breaches happen here more than anywhere else.
5. Paid advertising
The platform's own approval is not regulatory approval. Meta and Google will happily run an ad that breaches Philippine rules. Where the ad promotes a health product, the FDA advertising permit requirement applies and the permit number is expected to appear in the material.
6. Influencers and KOLs
The fastest-growing risk area. An influencer post promoting a regulated product functions as advertising regardless of how casually it is framed, so the product rules follow it. Material connections need disclosing, and the mandatory supplement statement travels with the claim rather than staying on your own account.
7. Doctors on camera
This is where clinics get the rule backwards. A physician explaining a condition or a procedure is providing professional information and is fine. A physician recommending a named product is commercial endorsement, which the Philippine Medical Association code prohibits whether or not the doctor is paid. Using a doctor's name or photograph in product promotion falls within it. Enforcement runs through the PRC.
8. Reviews and testimonials
There is no blanket prohibition of the kind Singapore has. The catch is that claims inside a testimonial are treated as your claims, so a review saying a treatment cured something creates the same problem as saying it yourself. Data privacy consent applies where a patient is identifiable.
9. Before and after photographs
Not banned outright, which lulls clinics into using them freely. They become a problem when they imply a typical or guaranteed result, at which point they are an unsubstantiated claim under consumer protection rules. If you use them, be specific about what was done over what period, and avoid suggesting the result is standard.
10. Promos, giveaways and discounts
Ordinary price advertising is not prohibited the way it is in Singapore. Promotional mechanics involving prizes or rewards are a different matter and require a sales promotion permit, which takes time and a fee. Plan around the lead time rather than discovering it a week before launch.
11. Email and SMS
Lightly regulated from an advertising standpoint but squarely within the Data Privacy Act. Consent, purpose limitation and the right to withdraw all apply, and patient contact details are sensitive personal information.
12. Prescription medicines, in any channel
Cannot be advertised to the public at all. Promotion is limited to publications intended for medical and associated professionals. A clinic post naming a prescription drug it uses is not neutral education and should be treated as advertising.
Quick reference
| Channel | Main constraint | Risk |
|---|---|---|
| Website service pages | No unsubstantiated outcome claims | Low |
| Educational blog content | Accuracy; avoid product claims | Low |
| Google Business Profile | Factual accuracy only | Low |
| Doctor explaining a condition | Information, not endorsement | Low |
| Organic social posts | Product claims trigger FDA rules | Medium |
| Reviews and testimonials | Claims inside are your claims | Medium |
| Before and after photos | Implying typical results | Medium |
| Email and SMS | Data Privacy Act consent | Medium |
| Paid ads for health products | FDA permit before publication | High |
| Influencer product posts | Permit, disclosure, mandatory statement | High |
| Giveaways and prize promos | Sales promotion permit | High |
| Doctor endorsing a product | PMA code bars it, paid or not | High |
| Prescription drug advertising | Public promotion not permitted | High |
Simplified for orientation. The exact wording of a claim changes the answer more often than the channel does.
Where the actual growth is
Most Philippine clinics worry about compliance and then do nothing, which is the worst of both. The searches that fill appointment books are local, specific and almost entirely uncontested by decent content.
Someone in Quezon City looking for a dermatologist near them, or asking what a procedure costs in Manila, is close to booking. Those searches are won by a complete Google Business Profile, a page for each service naming the area, consistent contact details across directories, and content answering what patients ask before they book. None of that requires a superlative, a result photo or a discount.
The compliant route and the effective route turn out to be the same route. That is unusual, and worth taking advantage of while your competitors are still arguing about whether they can post a before and after.
On timing, see what actually happens in the first 90 days. On being found when the answer comes from an assistant rather than a results page, see our guide to GEO and AEO.
Before you hire an agency
Ask what they would not be allowed to do for you. An agency that cannot name the FDA permit requirement or the endorsement prohibition has not read anything, and the consequence of a bad post lands on the clinic and the practitioner rather than on the agency.