Medical journal

Botulinum toxin: what the everyday word covers, and what the law says

"I'd like some botox." It is a common request, and there is nothing wrong with it: the word has entered everyday language. Yet it covers three different things: a brand name, a prescription-only medicine and a medical procedure that Belgian law regulates closely. Telling them apart helps you understand what a doctor can tell you, what he or she cannot offer you, and what you are entitled to ask.

Dr Selim Zengin, general practitioner, INAMI 1-07696-83-003

Published · Updated · 5 min read

"Botox": a brand name, not the name of a treatment

"Botox" is the trade name of a medicine: one of the products that contain botulinum toxin type A. Through constant use, the word has come to mean every injection of this kind, like a brand name that has turned into an ordinary noun. Yet it is neither the name of a treatment nor the name of the substance.

The substance is botulinum toxin type A: a protein produced by a bacterium, Clostridium botulinum, and purified to make a medicine. Injected into a muscle, it blocks the signal between the nerve and that muscle for a few months, so the muscle contracts less.

Several medicines containing botulinum toxin type A are registered in Belgium, under different brand names. That is why, on this website, I speak of botulinum toxin: it is the name of the substance, common to all of these medicines.

One substance, several medicines, several uses

These medicines are not only used to soften lines. In Belgium, some are reimbursed, under conditions, for neurological or urological indications: blepharospasm (involuntary contractions of the eyelids), dystonias, spasticity of the wrist or hand after a stroke, chronic migraine, and certain forms of urinary incontinence of neurological origin. Others are authorised for upper facial lines: frown lines, crow's feet and forehead lines.

One point matters a great deal: doses cannot be transposed from one medicine to another. The product information states that the units of one product are not interchangeable with those of other botulinum toxin preparations. The exact name of the product used is therefore not a detail.

A prescription-only medicine, for good reasons

Botulinum toxin type A is a prescription-only medicine. This status has a reason. In 2025, the European medicines authorities had the warnings in the product information strengthened: adverse effects related to the spread of the toxin away from the injection site have been reported, as well as cases of so-called iatrogenic botulism, that is, botulism caused by the treatment. The risk is higher in particular in children and in adults treated for spasticity with high doses.

If you have difficulty swallowing, speaking or breathing after an injection, see a doctor without delay.

A medical act reserved by law

In Belgium, a botulinum toxin injection for aesthetic purposes is a non-surgical aesthetic medical procedure. The law of 23 May 2013 reserves these procedures for the practitioners it designates: doctors, according to their title or, for those who already performed them before the law, according to recognised experience, and dentists for certain procedures inside the mouth. A beautician may not inject.

The Belgian Medical Council (Ordre des médecins) also points out that the doctor may not delegate this act to a non-doctor, and that you must be told that the procedure is medical: it is not a simple, risk-free beauty treatment.

Why no promotion is allowed

Two laws overlap. Article 9 of the law of 25 March 1964 on medicines prohibits advertising prescription-only medicines to the public. Article 20/1 of the law of 23 May 2013 prohibits advertising for the aesthetic procedures themselves. In 2017, the Court of Justice of the European Union confirmed that EU law does not preclude this ban.

Only professional information is allowed: truthful, objective, relevant, verifiable, discreet and clear. It may be neither misleading nor comparative, and may not use financial arguments. The Belgian Constitutional Court has specified that before-and-after photographs or testimonials amount to prohibited advertising when they appear in general communication; during a consultation, however, they may be used to inform you.

In practice, a "special offer", a time-limited discount or a brand name highlighted to attract patients has no place in a doctor's communication in Belgium. The French medicines agency, ANSM, lists promotion on social media and abnormally low prices among the warning signs of illegal injections.

What you are entitled to ask

  • Who performs the injection, and in what capacity.
  • The exact name of the medicine, the quantity injected and the batch number. For biological medicines such as botulinum toxin, the product information asks for the name and batch number of the product administered to be clearly recorded: this is what makes it traceable if a problem arises.
  • The package leaflet of the medicine: you may ask to read it.
  • Complete information before the procedure, in particular on the technique and the risks, set out in a written report, dated and signed by you and by the doctor, which becomes part of your medical record.
  • Your free consent, after this information. The Belgian law on patients' rights guarantees it.
  • Time to think: for injections, the law sets no waiting period, but nothing obliges you to decide on the same day.
  • What to do if a problem arises, and whom to call.

And products sold online?

A prescription-only medicine may not be sold online in Belgium. A product offered as "botox" on a website, on social media or through a messaging app therefore offers no guarantee as to what it contains. In France, the medicines agency again reported serious cases of botulism after illegal injections in 2025, and pointed out that products sold illegally may be counterfeit.

Sources.

  1. Belgian law of 23 May 2013 on the qualifications required for non-surgical aesthetic medicine and aesthetic surgery, in particular articles 3, 18 and 20/1 (Belgian Official Gazette, 2 July 2013; article 20/1 inserted by the law of 10 April 2014).
  2. Belgian Constitutional Court, judgment no. 1/2016 of 14 January 2016 (advertising ban, professional information, before-and-after photographs and testimonials).
  3. Belgian Constitutional Court, judgment no. 110/2015 of 17 September 2015 (scope of the law of 23 May 2013, authorised doctors), press release.
  4. Court of Justice of the European Union, order of 26 October 2017, case C-356/16 (Belgian ban on advertising aesthetic medical procedures and the Unfair Commercial Practices Directive).
  5. Belgian law of 25 March 1964 on medicines, article 9 (advertising of prescription-only medicines to the public).
  6. Belgian Medical Council (Ordre des médecins), National Council, opinion of 10 December 2022 on doctors working with beauty, wellness and care centres.
  7. Belgian law of 22 August 2002 on patients' rights, article 8 (free consent, given after prior information).
  8. Summary of product characteristics of a botulinum toxin type A authorised in Belgium for upper facial lines (FAMHP, text updated in December 2025): non-interchangeable units, warnings.
  9. Summary of product characteristics of another botulinum toxin type A (French public medicines database, ANSM): traceability, non-interchangeable units, prescription-only medicine.
  10. Belgian Centre for Pharmacotherapeutic Information (CBIP/BCFI): botulinum toxin, products registered in Belgium.
  11. Belgian Centre for Pharmacotherapeutic Information (CBIP/BCFI): reimbursement conditions of a botulinum toxin type A in Belgium (neurological and urological indications).
  12. European Medicines Agency, CMDh: scientific conclusions on botulinum toxin and changes to the product information (September 2025).
  13. ANSM (French medicines agency), "Illegal botulinum toxin injections: do not put your health at risk", 23 October 2025 (in French).
  14. Klein K, Stolk P. Challenges and Opportunities for the Traceability of (Biological) Medicinal Products. Drug Safety, 2018;41:911-918.
  15. CBIP, Folia Pharmacotherapeutica, June 2009: online sale of medicines (in French).

Related treatments.

General information article. It does not replace a consultation.