U.S. Advocacy Group Calls for Stricter Safety Measures and Labeling Changes for Botox and Rival Injections

14 December 2023

Public Citizen Petitions FDA to Address Safety Concerns and Misleading Promotional Statements

The U.S. advocacy group Public Citizen has turned its attention to the popular medical and cosmetic injection Botox, urging the Food and Drug Administration (FDA) to take action on safety and promotional issues surrounding the product. In a petition sent to the FDA, Public Citizen called for the removal of misleading promotional statements from Botox’s labeling and a strengthening of the black box warning for all approved Botox and related drugs. While Botox has long been the market leader in the medical aesthetics field, generating billions in revenue annually, Public Citizen is also targeting its rivals, including Daxxify, Jeuveau, Myobloc, Dysport, and Xeomin.

Public Citizen’s concerns primarily revolve around the safety risks associated with the use of neurotoxins in these injections. Neurotoxins, including the one found in Botox, are highly potent and can be used to treat both cosmetic and medical conditions. While they are commonly used for smoothing out wrinkle lines, they are also approved for medical use, such as treating migraines and incontinence. However, Public Citizen argues that there are serious safety risks involved and is calling for the FDA to address these concerns.

One of the key issues highlighted by Public Citizen is the potential complication of “systemic iatrogenic botulism” associated with Botox treatment and related drugs. This condition can cause muscle paralysis or weakness, posing a significant risk to patients. Despite the FDA’s of a black box warning in 2009, Public Citizen believes that the current warning does not go far enough in explicitly mentioning this risk. The group has a longstanding history with Botox and was responsible for petitioning for the drug’s black box warning back in 2008.

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In addition to safety concerns, Public Citizen is also targeting misleading promotional statements found in the labeling of Botox and Botox Cosmetic. Of particular concern is the claim that there have been no definitive serious adverse event reports of distant spread of toxin effect associated with recommended doses of these drugs for certain therapeutic indications and approved cosmetic uses. Public Citizen argues that this claim is not supported by regulators in other countries, such as Canada and the U.K., and that their analysis of the FDA’s safety database revealed adverse reactions suggestive of iatrogenic botulism associated with Botox treatment.


Public Citizen’s petition to the FDA raises important concerns about the safety and promotional practices surrounding Botox and its rival injections. As the market leader in the medical aesthetics field, Botox has generated significant revenue for AbbVie, but Public Citizen argues that stronger measures are needed to ensure the safety of patients. The group’s call for the removal of misleading promotional statements and a strengthened black box warning reflects their commitment to protecting consumers and promoting transparency in the pharmaceutical industry. It remains to be seen how the FDA will respond to Public Citizen’s petition, but their efforts serve as a reminder that rigorous oversight and regulation are crucial in maintaining public trust and safety.

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