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Less filler, less killer: regulation of the beauty industry

  • Legal Development 21 January 2020 21 January 2020
  • UK & Europe

  • Healthcare

Less filler, less killer: regulation of the beauty industry

The Scottish Government has launched a consultation on the regulation of non-surgical cosmetic procedures. 

The number of non-surgical cosmetic treatments carried out across Scotland and the UK has risen considerably over the years and continues to do so.  At present, these procedures are largely unregulated. Independent clinics run by a doctor, nurse, dentist, dental nurse, midwife or dental care professional are now regulated by Health Improvement Scotland. However, the procedures themselves are not currently regulated, which effectively means that anyone, anywhere, can carry out lip enhancements, dermal fillers and many other procedures without having to be registered with anyone, and without their premises being regulated. 

A number of pharmacists have now entered the cosmetic procedure field.  However, unlike doctors, nurses or dentists the pharmacists do not currently need to be registered with HIS. 

The consultation seeks views on the need for regulation, the need for non-qualified healthcare professions to be licensed and the regulation of pharmacists providing these services.  Responses are due by 30 April 2020. The full consultation paper can be viewed here.


This is a good first step by the Scottish Government.  At present, self-proclaimed beauticians, or anyone else, can go on a brief training course and start providing these treatments, wherever, whenever. 

Celebrities and social media may minimise or downplay the gravity of non-surgical cosmetic procedures. But things can, and do, go wrong.  The reported risks of procedures such as dermal fillers include infection, blocked arteries, necrosis, blindness and stroke.  Under-trained – or entirely untrained – individuals may fail to explain the risks. They may fail to get informed consent. They may fail to carry out acceptable treatment. And they may have failed to have appropriate insurance.

We have dealt with cases where seemingly straightforward procedures have gone wrong.  Regulation of this field will ultimately benefit everyone involved – the patients, the practitioners, and their insurers. 

At present, claims for these types of procedures performed by non-medical practitioners are largely dealt with under public liability insurance policies.  Regulation will hopefully enable more specific policies to be developed and offered to practitioners, whilst at the same time improving patient safety.

This is a welcome step towards filling the regulatory void in this growing industry. 


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