Brazil · Advertising framework
Influencer marketing for aesthetic treatments in Brazil
General market orientation, not campaign clearance. Research scope and dates
Product and service rules
Use the updated CFM advertising rules
Regulator guidance
Applies when: Physicians and medical establishments governed by CFM; dentists and other professions follow separate regulators.
CFM Resolution 2336/2023 permits specified information about services, prices and payment and conditional educational use of patient images. It does not permit sensationalism, guaranteed outcomes or every promotional mechanic. Verify the physician’s CRM and any claimed specialty/RQE and apply the full conditions for outcome images.
Sources: CFM medical advertising guidance: Resolution 2336/2023
Present educational outcome sequences, not isolated success images
Regulator guidance
Applies when: The advertiser is a physician subject to CFM rules; dentists follow the separate CFO framework.
CFM’s manual does not permit isolated before-and-after posts. Its educational sequence explains the condition, shows before and after examples and describes unsatisfactory results and possible complications. The manual specifies at least four patients for the before and after examples.
The resolution requires educational context about indications and factors influencing results, and prohibits image editing or enhancement that conflicts with its image rules. Patient permission alone does not replace these presentation conditions.
Sources: CFM — Practical medical advertising manual, Chapter XII; CFM Resolution 2336/2023
Channel rules
Check the complete consumer-facing message
Regulator guidance
Consumer advertising must be identifiable and must not be misleading or abusive, including through omission. Keep the factual, technical and scientific basis for the message. Review service promises, product claims, price conditions and imagery together; an influencer label does not remove these obligations.
Review the 2026 CONAR influencer framework
Regulator guidance
CONAR’s 2026 guide addresses advertising identification, truthful presentation, restricted sectors and campaign governance. Use it alongside the applicable ANVISA and professional rules; self-regulatory disclosure does not create permission to endorse a prescription medicine or promise a clinical result.
Sources: 2026 Guide to Marketing and Advertising by Digital Influencers
Health information has a sensitive-data regime
Regulator guidance
ANPD identifies health information as sensitive personal data under the LGPD. Determine an applicable Article 11 condition for that processing rather than relying automatically on an ordinary Article 7 marketing basis. Review patient stories, list building, tracking and sharing separately.
Sources: ANPD frequently asked questions
Brief the creator on the permitted message
Editorial recommendation
Check whether endorsements are permitted for the selected offer before contracting a creator. Record payments, gifts and affiliate links; specify the required advertising identification, approved claims, editing controls and takedown process.
Campaign workflow
Aesthetic Medicine & Cosmetic Procedures: prepare the review
Editorial recommendation
Separate the procedure, clinic, device, cosmetic and prescription medicine in the offer. Check restrictions on injectables and other products even when the headline advertises a consultation. Review realistic outcomes, risks, patient images and time-limited offers.
Keep a traceable campaign decision
Editorial recommendation
Keep one review record linking the offer, local market status, claim evidence, exact creative, media settings and any regulatory or professional clearance. Record who checked each condition. Reopen the review when the offer, claim, source rule or execution changes.
Pre-publication checklist
- Separate the procedure, clinic, device, cosmetic and prescription medicine in the offer.
- Check restrictions on injectables and other products even when the headline advertises a consultation.
- Review realistic outcomes, risks, patient images and time-limited offers.
- Record product or provider eligibility before approving claims.
- Archive the final creative and its evidence, permissions and review decisions.
- Assign an owner for source updates, complaints and prompt withdrawal of inaccurate material.
Scope and unresolved questions
- CFO patient-image conditions and the IVD-specific RDC 830/2023 route are now documented. The final effect of RDC 96 litigation remains unverified. Actual court orders, state/municipal licences, pharmacy codes, product warning assets and the legal basis for direct marketing still require a campaign review.
- This national baseline does not review every broadcaster rule, platform policy, regional licensing condition, promotion mechanic or data-transfer arrangement. No format-specific warning dimensions or durations should be inferred where none are supplied.
Research scope, introduction and dates
An aesthetic campaign through influencer collaborations in Brazil can advertise a clinic while also implying claims about a procedure, device or prescription medicine. Separate those elements first, then review outcome images, risks and commercial pressure.
Creator selection and commercial disclosure are only part of an influencer review. Examine the person's role, the spoken and visual claims, supplied benefits and the final publication together; a personal experience can still communicate a regulated claim.
General market orientation, not legal, regulatory or medical advice, a complete compliance plan or clearance of an advertisement. Actual requirements depend on the specific offer and campaign.
How to use this national baseline
Editorial overview
This framework combines researched national rules with editorial review steps. Federal ANVISA and professional advertising baseline; local licences and professional scope require individual checks. A visible channel workflow does not establish that the selected product or service may be advertised there. Read the category restrictions first.
The review date identifies when the cited provisions or regulator excerpts were checked. It does not mean that every local rule, exception, professional standard or platform policy has been reviewed.
Sources
- CFM medical advertising guidance: Resolution 2336/2023
Targeted source review; apply the cited provision to the exact offer and check subsequent changes before launch.
- Consumer Protection Code, Lei 8.078/1990
Targeted source review; apply the cited provision to the exact offer and check subsequent changes before launch.
- 2026 Guide to Marketing and Advertising by Digital Influencers
Self-regulatory guidance, not a statute. Announcement checked; detailed case-specific execution still needs the full operative guide.
- ANPD frequently asked questions
Targeted source review; apply the cited provision to the exact offer and check subsequent changes before launch.
- CFM — Practical medical advertising manual, Chapter XII
Targeted review on 25 October 2026. This date does not certify the currency of other sources or resolve local and campaign-specific requirements.
- CFM Resolution 2336/2023
Targeted review on 25 October 2026. This date does not certify the currency of other sources or resolve local and campaign-specific requirements.
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