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How England is Cracking Down on its Unlicenced Botox Problem

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There is an aesthetics regulation problem in the UK right now.

‘Lunchtime’ treatments seem to be getting more invasive. Videos on TikTok are filling our feeds with those with no prior medical training becoming injectors. And there are more reported botched treatments than ever. It’s clear that more needs to be done. The industry has seen exponential growth in the last decade and the regulations of it are struggling to keep up. 

The beauty and personal care industry industry is huge — a 24.5 billion to be exact — and touches many people’s lives from all different backgrounds so to say it’s complicated would be an understatement. Because the aesthetics industry in particular has been so fast growing (the UK aesthetics market being worth an estimated £3.6 billion), it has been left to self-regulate. 

Although measures have been introduced, there is still a lot to be done. But, of course, it’s not as simple as a quick fix policy. Making the industry a safer place for consumers whilst still supporting the practitioners and self-employed business owners is not a straightforward task. 

If you’re a little confused as to where we’re at with aesthetic regulations so far, I’ve broken down (hopefully) everything you need to know on a topline level. And we’ll be sure to keep you up to date when more details are released. 


What has been done so far with aesthetics regulations?  

The great news is that we’re moving in the right direction and organisations have worked tirelessly to make the industry a safer place already. Unfortunately, regulating an entire industry is no mean feat, nor a quick one. To dive into the future, it’s first helpful to see a timeline of what’s been happening thus far. This is by no means a comprehensive list (otherwise we’d be here all day), but here are a few key moments in the last few years. 

Let’s take it back to 2016 when we saw the introduction of the UK’s General Medical Council (GMC) guidance published for cosmetic doctors, which included recommendations like a ‘cooling off’ period and driving more awareness to the psychological impacts and motivations behind getting treatments.

Co-chairs Carolyn Harris MP and Judith Cummins MP set up the All-Party Parliamentary Group (APPG) Beauty, Aesthetics and Wellbeing group in 2019 to champion and challenge challenges the industry faces. The group undertook a year-long enquiry investigating safety and standards, and published its findings with 17 recommendations in 2021. 

The Joint Council of Cosmetic Practitioners (JCCP) also published its 10-point plan for regulation, mandatory training, clearer definitions, regulated social media advertising, and more. 

Later that same year, the Botulinum Toxin and Cosmetic Fillers (Children) Act was introduced in England thanks to pressure from orgs and lobbyists. This act made it a criminal offence to administer injectables to under 18s. Yep, it wasn’t illegal prior to then and a 2019 Vice investigation found that a staggering 90% of clinics they approached did not ask for age prior to booking an appointment. 

This isn’t perfect though, because no such laws exist in Wales, Scotland or Northern Ireland meaning younger people of any age can get fillers and Botox injected in those parts of the UK.


Image – Bethanybirnie/Stocksy


Fast forward to where we’re at now. In 2022, the Health and Care Act gave the Secretary of State of Health the go ahead to introduce a licensing scheme for non-surgical cosmetic treatments in England. This is where all of the work behind the scenes has been happening. This is no quick process, there are various inquiries and consultations happening to ensure all factors are considered. 

Organisations such as the British Beauty Council and British Association of Beauty Therapy & Cosmetology (BABTAC) have been instrumental in supporting the Department of Health & Social Care in the consultation and creating a new licensing scheme. But it takes time. As Victoria Brownlie, BABTAC chief policy officer explained to me, there were around 11,000 responses to the inquiry which is huge.


The issue with the current regulations 

You might be wondering whether it’s that much of a big deal that non-surgical procedures aren’t regulated. To put it bluntly, yes, it’s a problem and needs to be dealt with — there are a few reasons why. 

The first is that a vast number of people unknowingly believe that the industry is regulated. A 2022 inquiry conducted by the Beauty Backed Trust found that more than half of consumers believe that the industry is regulated. Meaning that people are potentially putting themselves in danger without knowing it. 

This lack of regulation is having real-life consequences. There were 3,000 complaints about botched aesthetics procedures in 2022, with two-thirds relating to dermal fillers and almost a quarter relating to wrinkle-relaxants, according to research conducted by Save Face

This is obviously dangerous as we don’t want procedures going wrong, particularly when those botching them don’t know how to rectify issues that arise. This ultimately puts strain on those properly qualified to fix these botched procedures — many of whom say that they’re doing more corrective treatments than ever before. 

“As it stands, the current regulations do not protect patients from the very real risk of serious injury or harm caused by practitioners offering cosmetic procedures without proper training or a low level of competence,” says aesthetics doctor Dr Miriam Adebibe

Social media has caused a rise in individuals with no prior medical background completing one-day courses to become injectors. “I am seeing more and more people on social media with extremely distorted facial features caused by excessive dermal filler treatment. This can cause compression of important structures, like the blood vessels feeding the facial tissues. Overstretching of the skin can cause it to break down and introduce infection,” explains Dr Adebibe


The new proposed 3-tier system 

When I sat down to speak with Brownlie, I’d mentioned that I felt like the regulations conversation and action has slowed down recently. When she noted that she disagreed and got talking about what’s happening behind the scenes, I was quick (and relieved) to be proven wrong. After all, there are 11,000 responses from the inquiry to get through (many of which were detailed) is not a quick job. “The complexities and scope of aesthetics treatments together with the speed of innovations make implementing a valid, robust, and enforceable scheme very challenging,” explains BABTAC CEO Lesley Blair

The government — along with the help of other industry professionals and bodies— has been working on creating its first step towards a more regulated industry: its 3-tier system. 

The proposed (it’s important to remember that none of this is set in stone yet) 3-tier system aims to set out green, amber and red categories to group together procedures that are deemed low, medium and high risk. Of course, all aesthetics procedures carry some risk but this hopes to make it clearer. 

Those procedures in the green list, deemed to be the lowest risk, can be carried out by practitioners with suitable qualifications meeting the standards. These procedures include microneedling, chemical peels (for the outermost layer of the skin only), non-ablative laser hair removal, and mesotherapy, to name a few. 

Amber procedures — where things get a little more complicated — have a medium risk, which means it must have relevant oversight by a named regulated healthcare professional. Proposed procedures here include botulinum toxin, semi-permanent dermal fillers, platelet rich plasma therapy, fat dissolving injections, chemical peels (medium depth), and many more. 

It’s being proposed that red procedures, carrying the highest risk of complications, are restricted to only qualified and regulated healthcare professionals only. These procedures include (a by no means exhaustive list) thread lifts of all kinds, hair restoration, chemical peels (at the deepest level, such as phenol peels), CO2 lasers, all IV infusions, and any procedures aimed at ‘augmenting any part of the body’.

As briefly mentioned in the amber category, the proposal recommends that any procedure requiring prescription-only medication is overseen by a qualified healthcare professional (at the very least). This includes things like botulinum toxin where the prescription-only medication is a direct use in the procedure, but also those used alongside a primary procedure to assist, such as lidocaine or hyaluronidase. 

The procedures within the 3-tier system are to be released following findings this year. The result of this is going to have a huge impact on the industry.


Image – Ohlamourstudio/Stocksy


The pros and cons of the 3-tier system

After learning about the 3-tier system, I was immediately interested to hear what the industry professionals made of the proposed solution. Of the few people I spoke to, summed up, I’d say there’s a collective cautious optimism. 


“I very much welcome more stringent industry regulations. It is a positive step forward for both, medically-led clinics like 111 Harley St. [a CQC regulated clinic] and the general public, who need to be assured their treatments are carried out by qualified healthcare professionals in a regulated environment,” says Agata Podwika, managing director for 111 Harley St. “Currently, there are too many grey areas, making choosing a practitioner difficult. As a responsible clinic, we value anything that reinforces safety in the industry and supports raising standards. I am keen to see tighter regulations to benefit patients who are at the centre of everything we do,” she adds.  

The system will ensure that those who offer aesthetic (non-surgical cosmetic) procedures are suitably knowledgeable, trained, and qualified, hold appropriate indemnity cover and operate from premises which meet the necessary standards of hygiene and cleanliness with the ultimate aim of safeguarding consumers,” says Blair

“I think it is a great start, it’s most likely not a perfect system and I think there will be a lot of discrepancy and people may think a treatment is lower than it is or higher than it is etc. I think it’s going to take time to change things significantly but it’s a good way to start,” explains Dr Ahmed El Muntasar, GP and award-winning cosmetic doctor. 



Podwika believes there are no cons to the new system. “There isn’t anything bad about this. It’s quite the opposite; this is an essential step to protect patients and help them identify who is appropriately trained and qualified to carry out the procedure. At the moment, there is a wide range of cosmetic procedures offered by non-qualified practitioners.” 

The Beauty Industry was one of the worst hit during the pandemic and subsequent economic crisis and much of the sector is still recovering. There is a risk of the legislation penalising reputable professional and safe businesses if the parameters set out by the scheme do not take all the relevant factors into consideration,” Blair adds. 

“I think it is going to be quite difficult to regulate large groups of practitioners in the UK that have

been unregulated for decades now. I think there’s going to be a lot of retaliation unfortunately and the risk of unregulated treatments still taking place,” explains Dr Ahmed


The future of the aesthetics industry 

As much as we’d all like to wave a magic wand and have the industry be the most regulated, safe and accessible place, unfortunately that just isn’t true to reality. 

We can’t underestimate the complexities of regulating the industry and doing so starting from the ground up. As Blair and Brownlie stated to me, the beauty industry was one of the worst hit financially by the pandemic and it is an industry predominantly made up of women who are self-employed. Whilst regulating the industry can only be a good thing in making it a safer place, we cannot ignore that no solution is perfect. 

There is still a lot to be hashed out, including what the sub-types of treatments will be included in each category. For example a chemical peel is the same treatment but the types of peels you can get come with various risks so determining all of these intricacies of each procedure takes lots of time. 

The logistics of getting oversight from a supervisor for certain procedures also hasn’t been cemented yet. “Whether it’ll mean you simply have to be on site, or whether it means you have to be within a certain distance away [from a supervisor] should anything happen requiring complication management, or just have to be on the other end of the phone,” says Brownlie. “That’s what’s being decided and will have massive cost implications.” This will also have big implications across the UK with the industry already being quite London-centric. 

What we don’t want happening is an aesthetics black market where patients are left even more vulnerable to those who want to cut corners and ignore the risks. 

“We strongly believe the grading classifications for each procedure require further breakdown in terms of levels of risk, scope of treatments, technology used and degrees of oversight required in order to safeguard the public,” says Blair. “The Enforcement & Monitoring of the scheme also presents its own challenges in terms of the sheer scope,” she adds. In addition to this, the lack of standardisation and legislation governing the training currently, “we believe a mandated national standard of fit for purpose training and qualifications for all practitioners must be developed.” 

Told you, it’s no quick or easy fix. There are lots of pros and cons when it comes to protecting both consumers and supporting beauty industry professionals. 


Meet the experts

Victoria Brownlie is Chief Policy Officer at the British Beauty Council. She has more than fifteen years of experience influencing government policy and lobbying on issues from animal welfare to local government, construction and business.


Dr Miriam Adebibe is an aesthetics doctor providing a personal service using aesthetics and nutrition to enhance your skin health. 


Lesley Blair is the Chair and CEO of BABTAC, she also belongs to and contributes to a number of industry groups, campaigning on issues that matter most to the beauty industry. 


Agata Podwika is managing director for cosmetics practice 111 Harley St.


Dr Ahmed El Muntasar is a GP and award winning aesthetician.


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Contributing Beauty Editor

Tori Crowther is a beauty and health journalist and qualified nail tech. The former beauty editor of Popsugar UK, Tori regularly write for titles like Allure, Glamour, Marie Claire, and Women's Health and is Contributing Beauty Editor at Live That Glow. When she's not interviewing derms or writing features, you can find her seeking out the best coffee outside of London.

Expertise: Nails, skincare
Education: Nottingham Trent University

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