What does the Undesirable Medical Advertisements Ordinance ban?
Last updated: October 2026. Last checked: 18 October 2026. The Undesirable Medical Advertisements Ordinance (Cap. 231) (opens in a new tab) bans three kinds of advertisement. We read the verified copy on Hong Kong e-Legislation, last updated 14 May 2026, for every rule on this page.
- Section 3: no ad likely to lead to the use of any medicine, surgical appliance or treatment to treat or prevent a disease in column 1 of Schedule 1 (except purposes in column 2), or to treat anyone for a purpose in Schedule 2.
- Section 3B: no ad for an orally consumed product that makes a Schedule 4 claim, or any similar claim, except as column 2 allows.
- Section 4: no ad offering, canvassing or inviting the procuring of a miscarriage, unless published with the Director of Health's written authority.
The word advertisement is wide. The ordinance defines it to include any notice, label, document or announcement made orally or by light or sound, and the Department of Health's UMAO FAQ (opens in a new tab) says this covers newspapers, signboards, radio, television and the internet. Clinic websites, social posts and paid search ads are therefore all in scope.
Which Hong Kong rules apply to a clinic ad?
Four layers can apply to one clinic ad: the ordinance itself, the professional code of whoever practises there, the Trade Descriptions Ordinance for truthfulness, and the privacy law for any lead form. The table sums up what each rule means in practice.
| Rule | What it means for ads | Source |
|---|---|---|
| Section 3 and Schedule 1 | No ads for treating or preventing listed diseases, including tumours, heart and cardiovascular disease, diabetes and skin, hair or scalp disease, beyond the narrow purposes column 2 allows | Cap. 231 |
| Section 3 and Schedule 2 | No ads for treatments for gynaecological purposes, sexual virility or fertility, restoring lost youth, correcting deformity or surgically altering appearance | Cap. 231 |
| Section 3B and Schedule 4 | Six groups of claims for oral products are banned or limited to four set wordings each | Cap. 231; Drug Office FAQ |
| Section 4 | Abortion ads are banned unless the Director of Health authorises them in writing | Cap. 231 |
| Medical Council Code, section 5 | Doctors' information must be accurate, factual, balanced and not exaggerated, comparative or unduly persuasive | Medical Council of Hong Kong |
| Dental Council Code, section 1.2 | Dentists' information must not be exaggerated, laudatory or claim undue superiority | Dental Council of Hong Kong |
| Trade Descriptions Ordinance (Cap. 362) | Whether an ad is truthful or misleading is a separate question, enforced by Customs and Excise | Drug Office FAQ |
| PDPO Part 6A | Personal data cannot be used for direct marketing without informed consent | Privacy Commissioner |
Which diseases and purposes can clinics not advertise treatments for?
Schedule 1 lists 14 groups of disease, and for five of them no advertising purpose is allowed at all: tumours, venereal disease, heart and cardiovascular disease, genito-urinary disease and endocrine disease, including diabetes. The other nine allow only the narrow purposes in column 2, such as relief of common cold symptoms or symptomatic relief of headaches.
Item 14 matters most to skin and aesthetic clinics. It covers any disease of the skin, hair or scalp, and column 2 permits only listed minor purposes such as preventing pimples, external treatment of eczema or skin allergies, and treating dandruff by external applications.
Schedule 2: three banned advertising purposes
Schedule 2 lists three purposes for which no medicine, surgical appliance or treatment may be advertised: inducing menstruation or treating other gynaecological or obstetrical disease; promoting sexual virility, desire or fertility, or restoring lost youth; and correcting deformity or surgically altering a person's appearance.
For aesthetic marketing, the last two items carry the weight. Cosmetic surgery ads fall within section 3 directly, and anti-ageing headlines can read as restoring lost youth. The text names surgical alteration, so for non-surgical procedures we treat wording as needing review rather than as automatically safe. Our aesthetic clinic marketing in Hong Kong work starts from this list.
What health claims can oral products make in Hong Kong?
Since 1 June 2012, Schedule 4 has banned or restricted six groups of claims for any product taken orally as a pill, capsule, tablet, granule, powder, semi-solid or liquid. Claims about breast lumps, the genito-urinary system and the endocrine system are not allowed in any circumstances.
Claims about blood sugar, blood pressure and blood lipids or cholesterol are allowed only in four prescribed sentences each, such as "This product is suitable for people concerned about blood sugar." The Drug Office FAQ is clear that the exact wording must be used, and that claims to a similar effect are caught too.
Products not registered under the Pharmacy and Poisons Ordinance or the Chinese Medicine Ordinance must also carry the disclaimer set out in Schedule 4. The Drug Office's supplementary guidelines (opens in a new tab) on the six groups of claims give further examples of products in scope.
Can Hong Kong doctors advertise on social media?
Only within narrow limits. The Medical Council of Hong Kong Code of Professional Conduct (opens in a new tab) (revised October 2022) does not permit practice promotion to people who are not a doctor's patients, except in the ways section 5.2.3 sets out or with the Council's prior approval.
Those ways include bona fide announcements of starting or changing a practice in mass media and social media, carrying only the information Appendix H permits and no photographs, plus practice websites that follow the same rules. Letters of gratitude from patients that identify the doctor should not be published in mass media or social media.
Any information a doctor gives the public must be accurate, factual, objectively verifiable and balanced. Section 5.2.1.2 says it must not be exaggerated or misleading, claim superiority over other doctors, claim uniqueness without proper justification, be sensational or unduly persuasive, or generate unrealistic expectations.
Do the rules cover clinic groups?
Clinic groups are not outside these rules. Under section 18 of the Code, the Council can discipline a doctor where an advertisement in an organisation's name is in effect promotion of that doctor's practice, and doctors linked to an organisation must exercise due diligence over its advertising.
A doctor's fees or contact details must never appear in the organisation's promotional materials.
What do the Dental Council rules add for dental clinics?
Dentists follow a parallel code. Section 1.2.2 of the Dental Council of Hong Kong Code of Professional Discipline (opens in a new tab) says practice information must not be exaggerated or misleading, comparative with other dentists, laudatory, persuasive or sensational, or generate unrealistic expectations.
Section 1.2.3.3 adds that dentists must never give the impression that they, or institutions they are associated with, have unique or special skills or solutions. The Council also publishes separate guidelines on personal web pages and social media for dentists. Our dental clinic marketing in Hong Kong work applies both codes alongside Cap. 231.
What are the penalties for breaking Hong Kong's medical advertising rules?
Breaching section 3, 3B or 4 is a criminal offence. Under section 6 of Cap. 231, a first conviction carries a fine at level 5 and imprisonment for 6 months; a second or later conviction under the same section carries a fine at level 6 and imprisonment for 1 year.
Schedule 8 of the Criminal Procedure Ordinance (Cap. 221) (opens in a new tab) sets level 5 at HK$50,000 and level 6 at HK$100,000. Obstructing a Department of Health inspector carries a fine at level 3, which is HK$10,000.
| Offence | Maximum fine | Imprisonment |
|---|---|---|
| First conviction under section 3, 3B or 4 | Level 5 (HK$50,000) | 6 months |
| Second or later conviction under the same section | Level 6 (HK$100,000) | 1 year |
| Obstructing an inspector or withholding required information | Level 3 (HK$10,000) | None stated |
Liability reaches the advertiser, not only the publisher. If an ad names a person as able to provide the treatment, or gives their name, address or phone number, that person is presumed to have caused it to be published until the contrary is proved.
What does the PDPO require on clinic lead forms?
When a clinic collects personal data directly, the Privacy Commissioner's overview of the PDPO (opens in a new tab) says it should tell people whether supplying data is obligatory, the purpose, the classes of people it may be transferred to, and how to request access and correction.
Using that data for direct marketing needs informed consent under Part 6A. Silence is not consent, and the person must be told of the right to opt out.
The Commissioner states that breaching the direct marketing rules can mean a fine of HK$500,000 and 3 years' imprisonment, or HK$1,000,000 and 5 years where data is provided to a third party for gain.
What should a clinic check before a Hong Kong ad goes live?
Run every ad, landing page and lead form through the same short list before launch. The Department of Health has no pre-approval system and will not comment on individual cases, according to its UMAO FAQ, so the check sits with the clinic and its agency.
- Does any claim touch a Schedule 1 disease, including skin, hair or scalp disease, beyond the purposes column 2 allows?
- Does any line promise to restore lost youth, enhance sexual function or fertility, or alter appearance surgically?
- For oral products, is every blood sugar, blood pressure or cholesterol claim one of the four prescribed sentences, with the disclaimer if unregistered?
- Is any wording exaggerated, comparative, superior, unique or likely to raise unrealistic expectations under the Medical or Dental Council code?
- Are patient letters of gratitude that identify a doctor kept out of social media and mass media?
- Is every efficacy statement truthful, with no reliance on a study to justify a prohibited claim?
- Does the lead form explain the purpose, transferees and access rights, and ask for opt-in consent before direct marketing?
Our free Hong Kong medical ad checker turns the first five questions into automated flags for ad copy. For a worked example of compliant Meta and Google campaigns, see our Hong Kong aesthetic clinic case study.
Is this page legal advice?
This page is general information and not legal advice. Laws, codes and guidance change, so check the current text on Hong Kong e-Legislation and with the relevant council, or ask a Hong Kong lawyer, before relying on it for a decision.
When the rules are clear, we build compliant campaigns through our Meta ads service in Hong Kong and our Google Ads service in Hong Kong.
A Chinese version of this guide is 香港醫療廣告規則.