In January 2014 the ASA ruled on a health and beauty clinic's website. Its homepage had listed "Botox" among its treatments, with a link to a page about the medicine. The clinic had since swapped the word for "wrinkle softening treatment". But visitors who clicked the new label were still "connected directly to content about Botox". The ASA held that removing the word "did not itself resolve the issue", and upheld the complaint.
A price list raises the same question. What it says matters, and so does the route a visitor takes to reach it.
Checked against the regulators' published guidance on 1 October 2026. WebAsk is a web agency, not a law firm. This summarises published guidance; it is not legal advice. We name the medicine here only to discuss the rules on advertising it.
So, can I put Botox on my price list?
TL;DR
CAP's FAQ says a website price list that names Botox "might be acceptable" if clients "can only get to the price list after going through a page promoting a consultation", but a price on the homepage, or "a direct link to 'Prices' which mentions Botox", "is unlikely to be acceptable". CAP's advice of 29 October 2025 adds that the list "should not include product claims or encourage viewers to choose a product based on the price".
The short answer: it depends on the route
Botox is a prescription-only medicine, or POM. The CAP Code, which the ASA enforces, prohibits advertising POMs to the public (our post on the rule covers it). CAP's FAQ on the medicine (CAP News, 23 January 2020) says the rule applies to "even your own website", with "some small exceptions".
For a price list on a website, the FAQ's answer is short:
"If it's on your website, it depends. If you mention the price on the homepage or include a direct link to 'Prices' which mentions Botox, this is unlikely to be acceptable. However, if clients can only get to the price list after going through a page promoting a consultation (as above), then this might be acceptable."
"Might be acceptable" is the most the FAQ offers for the gated route.
The "as above" points back to the FAQ's answer on websites in general. It gives the example of a "wrinkle treatment consultation" on your homepage. One condition is that "it is clear that the consultation may or may not lead to the provision of Botox".
What CAP's guidance says, word for word
Three CAP pages set out the conditions for a price list. They sit on the ASA's website, but they are CAP's guidance, not ASA rulings. Their strength differs, so each quote stays with its own page. "Not covered" means the page's passage on price lists is silent on the point.
| Question | CAP Bitesize (undated; April 2025 disclaimer) | FAQ (CAP News, 23 January 2020) | CAP's advice (29 October 2025) |
|---|---|---|---|
| May the list name it? | "You can mention Botox in a price list as part of a broader range of treatments" | "If it's on your website, it depends." | "Marketers' websites may include a price list with a range of treatments available, including Botox" |
| The homepage | "They shouldn't be able to view pricing for Botox directly from the homepage." | "If you mention the price on the homepage or include a direct link to 'Prices' which mentions Botox, this is unlikely to be acceptable." | "No reference to a POM should be made … on the homepage of a website"; homepage small print should not "directly link consumers to a page where they are referenced" |
| The gate | "only after the user has clicked through the consultation pages" | "if clients can only get to the price list after going through a page promoting a consultation (as above), then this might be acceptable" | Not covered |
| Clicks | "ideally two clicks from the homepage", said of the page on treatment options, not of the price list | No number: "after going through a page promoting a consultation" | Not covered |
| What the list may say | "Purely informational with no promotional content" | "a price list with an incidental reference to Botox alongside its price" | "should not include product claims or encourage viewers to choose a product based on the price" |
Bitesize is the firmest of the three about the gate:
"Making sure users can't access information about Botox without going through the consultation journey is essential for compliance."
What the words do not say
It is easy to harden these words in a summary. Our own planning notes did, until we checked them against the pages on 28 September 2026. Here is what the pages do not say.
- No "at least two clicks". Bitesize says "ideally two clicks from the homepage". "Ideally" is a preference, not a floor, and Bitesize says it of the page with treatment information, not of the price list. No page we read sets a minimum number of clicks.
- "Only" means the gate, not a count. Bitesize and the FAQ both say "only", and both tie it to the consultation, not to a number of clicks.
- No "primary navigation". None of the pages we read uses the phrase. The nearest line is the MHRA's, about a clinic's homepage: "Links and navigation aids may be given for particular conditions and diseases but not to specific POMs" (Blue Guide, Appendix 6, November 2020).
- No promise. Bitesize introduces its route as "a safer approach". The FAQ says "might". Neither says a gated list will be acceptable.
Two exclusions that do not settle it
Medicines law leaves "price lists, provided that no product claim is made" out of what counts as an advertisement (Human Medicines Regulations 2012, regulation 7). The CAP Code's scope leaves out "price lists unless they advertise another product or a promotion or are visible in a marketing communication". Neither line says a price list on a website is fine. The FAQ still answers the website case with "it depends".
In the 2014 ruling at the top of this post, the ASA noted the law's exclusion for factual "reference material". It checked the site's claims against it, and still upheld the complaint.
The route from homepage to price list
Each row gives the sentence the step rests on, and whose words those are. A site built this way follows the route CAP's guidance describes. That is still not a promise: the FAQ's word is "might".
| Step | What sits there | The sentence it rests on | Whose words |
|---|---|---|---|
| 1. Homepage | The consultation, for the concern. No mention of the medicine, and no price for it | "Advertise the consultation (not the treatment) on your homepage." "No mention on your homepage". Also: "If you mention the price on the homepage … this is unlikely to be acceptable." | CAP Bitesize; CAP's FAQ |
| 2. Consultation page | What the consultation covers, and that it may or may not lead to the medicine | "From there, link to a separate page with more information about the consultation." Also: "the consultation may or may not lead to the provision of Botox" | CAP Bitesize; CAP's FAQ |
| 3. Treatment-options page | Balanced, factual information on the options, the medicine among them | "That page can then link to a further page (ideally two clicks from the homepage) which includes factual, balanced information about treatment options – including Botox." | CAP Bitesize |
| 4. Price list | Reached only through the consultation pages | "only after the user has clicked through the consultation pages"; "if clients can only get to the price list after going through a page promoting a consultation (as above), then this might be acceptable" | CAP Bitesize; CAP's FAQ |
| 5. Where the list sits | No nearer the homepage than the treatment-options page | No page we read sets a click count for the price list. "Ideally two clicks" is said of the treatment-options page | Our reading |
| 6. The rows | The medicine as one row in a range of treatments, with a price and no claims | "as part of a broader range of treatments"; "should not include product claims or encourage viewers to choose a product based on the price" | CAP Bitesize; CAP's advice, 29 October 2025 |
| 7. A line beside the list | The viewer's choice will not be prescribed if it is not suitable | "The information associated with price lists should make it clear that the viewer's preferred option will not be prescribed if it is not suitable." | The MHRA (Blue Guide, Appendix 6, November 2020), not CAP |
| 8. No way round | No page that names the medicine can be reached, from any link on the site, without the consultation pages | "website ads should not provide separate information on Botox which could be navigated to directly, without consumers also viewing information about the consultation process" | The ASA (Dermaskin Clinics and HB Health of Knightsbridge rulings, 15 January 2014) |
| 9. Menus, footers, titles | The medicine in none of them, and no menu or footer link straight to the list | No page we read deals with menus, site-wide footers or page titles. Nearest lines: Bitesize on "small print", CAP's advice on homepage small print, and the MHRA on "links and navigation aids" | Our reading |
Steps 5 and 9 are ours. The section on menus, footers and search results below explains step 9.
One trap with gates. In a 2026 ruling on weight-loss medicines, the ASA called a page that "simply asked consumers to select" between two options "a filtering page". It treated the page after it, which showed the medicines, as "akin to a homepage" (Juniper, 8 April 2026). That ruling was about a paid social media ad and different medicines. Our reading: a gate with nothing about the consultation on it may not be what Bitesize means by "the consultation pages".
What the price list itself may say
CAP's advice of 29 October 2025 sets two limits on the list:
"Marketers' websites may include a price list with a range of treatments available, including Botox, but the price list should not include product claims or encourage viewers to choose a product based on the price."
The advice does not list what would encourage that choice, and we do not add a list.
The ASA set a similar test in a 2012 ruling. It said "a factual list of prices was acceptable under the Code, provided the list did not include product claims or actively encourage viewers to choose a product based on the price" (Skinboost, 22 February 2012). The 2012 ruling says "actively encourage"; the 2025 advice says "encourage". The same ruling found that a softer name in the price list, read with the site's other references to the medicine, pointed to it. Our post on the advertising rule covers that case.
Bitesize says the reference must be "Purely informational with no promotional content – like the kind of thing you'd read in a patient information leaflet". The FAQ says: "Take care not to give the Botox references any prominence".
The MHRA adds a point about the words around the list. Its guidance says the information that goes with a price list "should make it clear that the viewer's preferred option will not be prescribed if it is not suitable". That is the MHRA's guidance, not CAP's.
Menus, footers and search results: where the guidance runs out
The pages above cover the homepage, small print and direct links to prices. Beyond that, here is what the sources say, and where our reading takes over.
Footers and small print
CAP's advice says small print at the bottom of a homepage "should not refer to POMs or directly link consumers to a page where they are referenced". That line is about the homepage. Bitesize's list has no such limit: "No mention in hover text, small print or testimonials". Our reading: a site-wide footer is small print on every page, and because the same footer shows on the homepage, CAP's line on links reaches it there. So we would keep the medicine, and any direct link to the price list, out of the footer.
Menus
None of the pages we read mentions menus. The MHRA's line on "links and navigation aids", quoted above, is about the homepage. In the 2026 ruling above, the ASA cited the same point from Chapter seven of the MHRA's Blue Guide. A main menu shows on the homepage. So we read a menu item that names the medicine, or a "Prices" item that goes straight to a list naming it, as the kind of link the FAQ calls "unlikely to be acceptable". We would keep both out of the menu.
Ads and landing pages
CAP's advice on weight-control medicines (29 May 2026) says there is "a small exemption to the inner pages of a clinic or pharmacy's own website (but not the homepage or a proactively linked landing page)". In Juniper, the ASA "understood that landing pages from paid-for ads on social media were akin to a homepage, for the purposes of the MHRA's Blue Guide". Both are about weight-loss medicines. CAP's general advice on prescription-only medicines (30 September 2026) puts the point in general terms: "Even if a digital ad does not include content which promotes a POM to the public, if that ad links directly to website content which does, it still might be considered to breach the Code." Our reading: do not point a paid ad or a sponsored search result at a price list or treatment page that names this medicine.
Page titles and descriptions
A search result can show a page's title and description to someone who has not seen a consultation page. So we would keep the medicine out of every page title and meta description on a clinic's site. That is our rule. Under a heading on meta tags and meta descriptions, the MHRA says its "main focus is the content of the website, rather than the competitive tools used to increase awareness of the website which are not usually prominent in customer views". Our rule is stricter than that stated focus.
Booking buttons
No guidance page we read on this medicine deals with a "Book" button on a price list. The MHRA says: "It is permissible to use icons to encourage people to undertake a medical consultation." It says icons "encouraging the purchase of POMs", such as "Buy Now" and "Add to Basket", "should not be used on websites offering POM treatments". In a 2015 ruling about other medicines, the ASA held that a page "presented the POMs as a choice for the consumer to select prior to GP consultation" (Lloyds Pharmacy, 4 March 2015). Our reading: the booking button books the consultation, and no row of the price list books the medicine.
What the guidance leaves open
Bitesize says there should be "No mention in your price list (unless suitably gated)". No page we read defines "suitably gated". For a query the FAQ has not covered, it points to CAP's Copy Advice team. Its standard service is free, and it says its advice "is not binding on you, CAP or the ASA".
What this costs you in search, and why we would not work around it
Built this way, the price page is not meant to rank for the medicine's name. Its title leaves the name out, it sits behind the consultation pages, and no ad points at it. That is a real cost.
The page that can compete is the consultation page, on the concern. CAP's advice gives "a consultation for the treatment of lines and wrinkles" as a claim that "is likely to be considered acceptable". A consultation page can be built around that wording, and it can be linked from the homepage and the menu.
There are ways to put the price in front of more searchers: a main-menu "Prices" link straight to the list, a page title that names the medicine, a paid ad that lands on the list. Each one puts the name, or the list that names it, in front of someone who has not been through a consultation page. Bitesize's principle is that "a consumer casually browsing your site should not be able to find any reference to Botox easily." We read each of those shortcuts as a way around that principle, so we would not build them. That is our judgement, not a quoted rule.
We cannot put a number on the cost. We have no traffic data for this search, and we will not guess.
Where to start
- Walk the route on your own site. Start at the homepage and try to reach the price list without passing a consultation page. Try the menu, the footer, and any ad that points at the list. Each way through is a shortcut to close.
- Read the list as a stranger would. Check each row for claims, and for anything that pushes a choice on price.
- Get a second look. CAP's Copy Advice team, above, takes questions about your ad or website. Our page for aesthetic clinics sets out the consultation-first structure, and the whole-site checklist covers the rest of a clinic site. The free audit includes a rules check for clinics that gives no legal verdict. Or get in touch.