Botulinum toxin is a prescription medicine. Under section 19 of the Medicines Act 1981 it may be administered only on a prescriber's directions or a standing order, and contravention is an offence. The Nursing Council told the Health and Disability Commissioner that it can only be given by a medical practitioner, a dentist, a registered nurse or a nurse practitioner working under standing orders, and that any nurse must practise within their scope and have relevant training. Dermal filler is usually a medical device. It does not require a prescription, and a standing order is not required by law.
Silk Clinical's injector is Shontelle Prasad RN.
The New Zealand rules
In 20HDC01927 the Commissioner found a doctor in breach after directing an unregistered employee to inject botulinum toxin.
Medsafe has stated that dermal filler products are usually, though not exclusively, categorised as medical devices under the Medicines Act, that they do not have to be approved for use, and that their access and use is not restricted to trained healthcare professionals under the Medicines Act, depending on the circumstances. That position was reported in December 2024 alongside the Medical Products Bill then being flagged. Advice that filler should only be injected by a doctor, dentist or nurse is professional guidance, not a Medicines Act lock for devices.
Dentists, dental specialists, oral health therapists and dental hygienists may administer botulinum toxin type A and dermal fillers as an advanced area of practice after extra training, confined to the orofacial complex and associated structures. Oral health therapists and dental hygienists need a standing order for botulinum toxin. For dermal fillers the Dental Council requires a similar arrangement even though the law does not.
Cosmetic medicine is not a separate medical specialty. Doctors, nurses and dentists are each regulated by their own responsible authority, as the New Zealand Society of Cosmetic Medicine sets out. To perform Category 2 non-surgical procedures, including botulinum toxin and dermal fillers, a doctor must be vocationally registered in a relevant surgical scope or dermatology with training in non-surgical procedures, or be an FRNZCGP and NZSCM member, or work in an approved collegial relationship. That is the Medical Council's November 2017 statement on cosmetic procedures, still live on 23 August 2026. NZSCM is a professional body for doctors. It does not set nurses' or dentists' scopes.
How to verify a practitioner
Check the public register that matches the title for current registration, scope, conditions and an annual practising certificate.
Nurses: Nursing Council register of practising nurses
Doctors: Medical Council register of doctors
Dentists and oral health practitioners: the Dental Council register.
Silk publishes Shontelle Prasad's registration as NCNZ 301636 on her profile.
What to ask at consultation
Ask who will inject you. If botulinum toxin is proposed, ask who issues the standing order. Ask where hyaluronidase is kept, what the clinic does if a vessel is occluded, and whether they will treat you if they think you should wait.
A consultation is an assessment, not a promised look. For training questions and red flags, use Choosing a nurse injector with this page.
What a clinic cannot advertise
Under sections 57 and 58 of the Medicines Act, a medical advertisement must not claim, indicate or suggest that a medicine, medical device or method of treatment is or has been used or recommended by a practitioner, nurse or pharmacist, or that it has beneficially affected the health of a particular person. Advertisements must also not state or suggest that medicines or medical devices cannot harm any person. From 1 July 2026 the Therapeutic and Health Advertising Code applies in full to all advertising.
This page carries no product name, no product price and no purchase button.
Silk Clinical is a nurse-led clinic. Shontelle Prasad RN administers botulinum toxin under a standing order, and dermal filler as a medical device in a clinical setting. That is the clinic's model, not a claim that every filler injection in New Zealand must be given by a registered nurse.
Book a consultation if you want to discuss whether treatment is appropriate for you.
Sources checked 23 August 2026. Re-check if a Medical Products Bill, or a replacement of the November 2017 Medical Council statement, comes into force.
Filed underregistered nurseregulationstanding ordersdermal filler
