The future of regulation in cosmetic surgery

The time is right for practitioners performing aesthetic treatments to be regulated, writes Dr Paul Charlson

Botulinum toxin: guidance on remote prescribing tightened up (Image: CC Studio/SPL)
Botulinum toxin: guidance on remote prescribing tightened up (Image: CC Studio/SPL)

In the UK, cosmetic medicine is currently unregulated and lay people can perform procedures without training, using unlicensed products. The DH is now supporting a Joint Council of Cosmetic Practitioners (JCCP), whose task is to oversee procedures and maintain a register of practitioners, with the aim of helping to regulate this rapidly developing industry.

Key words 

Aesthetic, botulinum toxin, cosmetic, dermal filler, regulation

Aesthetic medicine is becoming increasingly popular and more practitioners are seeking to provide a range of treatments. However, in the UK, the industry has remained unregulated. 

Anybody in the UK can legally inject anybody else and there is much anecdotal evidence of lay people, such as beauticians, injecting dermal fillers or using lasers and causing damage.  

Current guidance

There are relatively few barriers to non-clinicians practising cosmetic procedures. One is obtaining botulinum toxin, which is a prescription medicine. The GMC has tightened its guidance on remote prescribing, which used to be fairly common practice for botulinum toxin. 

Its guideline states that clinicians must undertake a physical examination of patients before prescribing non-surgical cosmetic medicinal products or other injectable cosmetic medicines, and must not prescribe these by telephone, video link or online.1 

As non-prescription medical devices, dermal fillers are easier to obtain. Many suppliers require some form of identification to prove the person ordering the product is a clinician, but there are ways to circumvent this. For lasers and other light sources, such as intense pulsed light, regulation is patchy, partially carried out by local authorities. 

The 2013 Keogh review of cosmetic procedures, which covered non-surgical interventions, stated: ‘In fact, a person having a non-surgical cosmetic intervention has no more protection and redress than someone buying a ballpoint pen or a toothbrush.’ It also stated that ‘dermal fillers were a crisis waiting to happen’.2

As a result of this review, the government asked Health Education England (HEE) to report on standards of qualification for people in the cosmetic industry providing botulinum toxin and dermal fillers, laser and other light treatments, peels and hair restoration procedures. 

Future regulation

The HEE report covers every level of practitioner and the qualifications required for them to deliver specific treatments.3 Provision has been made for existing practitioners and new entrants at all levels of clinical skill. When implemented, this will provide the public with some protection and help to prevent those not qualified from providing treatments. 

Although there is understandable anxiety, among doctors in particular, that non-clinicians will still be able to legally inject patients, it is likely that it will become increasingly difficult for unsupervised practitioners who are not clinicians to inject, because of their inability to obtain insurance. 

Even supervised non-clinicians will need a supervising clinician, who will be ultimately responsible for their actions. This should ensure better standards. 

The British College of Aesthetic Medicine and British Association of Cosmetic Nurses, supported by the DH, have now started work on developing the JCCP. 

The aim is to oversee adherence to the HEE standards and provide a register of practitioners meeting those standards. It will also ensure the public are aware of the potential problems. 

The JCCP might also accredit bodies providing training and qualifications, another currently unregulated activity. A clinical standards board is envisaged, to work in parallel to the JCCP. This will be clinician led and will look at developing new standards for procedures as they evolve, working with a medical devices advisory group. 

It remains to be seen if the JCCP can succeed. The real prize would be to make cosmetic medicine a specialty recognised by the GMC, with a defined career path. 

  • Dr Paul Charlson is a GP with a special interest in dermatology in Yorkshire and medical director of Skinqure Clinic

Competing interests: Dr Charlson is president of the British College of Aesthetic Medicine and medical director of Skinqure Clinic, which provides aesthetic treatments


1. GMC. Good Medical Practice. Prescribing guidance: remote prescribing via telephone, video-link or online. London, GMC, 2013.

2. DH. Review of the Regulation of Cosmetic Interventions. London, DH, April 2013. 

3. Health Education England. New qualifications unveiled to improve the safety of non-surgical cosmetic procedures. London, HEE, 8 January 2016. 

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