Campaigners received a record number of complaints about non-surgical cosmetic procedures last year, raising fears over how the public will be protected during the period before a new licensing regime is implemented.

Calls made by MPs to speed up the introduction of the regime, which would bring in consistent standards that individuals carrying out procedures such as Botox injections and dermal fillers will have to meet, as well as hygiene and safety standards for premises, were rejected in February by the Department of Health and Social Care.

There are now fears that the scheme could take up to three years to implement, during which people will continue to be put at risk of harm.

Save Face, a national register of accredited practitioners who campaign for improved safety standards, said it received 2,824 complaints last year regarding unregistered practitioners. The figures, which cover reported complications from treatments, among other issues, are up from 2,436 in 2021 and 2,083 in 2020.

Dermal fillers made up 69 percent of the complaints last year, followed by botulinum toxin injections, of which the best-known brand is Botox.

Ashton Collins, director of Save Face, said calls by the Commons’ health and social care committee for the government to introduce a licensing regime by July 2023 had been unrealistic.

But she urged the government to do more in the meantime to protect people. For instance, they “could be putting out a proper awareness campaign to anybody thinking of having these treatments”, she said.

Ashton Collins, director of Save Face, said the laws currently in place for non-surgical cosmetic procedures are not being followed or enforced

Ashton Collins, director of Save Face, said the laws currently in place for non-surgical cosmetic procedures are not being followed or enforced

“They could also make it a mandatory requirement for [practitioners] to have malpractice insurance, which isn’t a legal requirement at the moment, so at least when someone has something that goes wrong that is going to cost thousands of pounds to rectify, they have an avenue to get compensation.”

Collins said the laws currently in place are not always followed or enforced. “If any new laws are going to be treated in the same way as the current laws that regulate the sector, it’s pointless. The legislation to prevent remote prescribing of Botox and the illegal importation of unlicenced medicines and medical devices are grossly under enforced and fails to protect those who have fallen foul to bad practice.” she said.

Save Face hears of dozens of cases every month where clients have not had a face-to-face appointment with a registered prescriber before having Botox injections, which is a legal requirement. It is also illegal for anyone aged under 18 to have Botox or dermal fillers, yet Collins was aware of a recent case that was not investigated after being reported.

There were fewer complaints about practitioners using unlicensed botulinum toxin injections after The Times published an undercover investigation last year detailing how illegal products were being used by practitioners to cut costs. The complaints still being received include the worst case the organisation has ever come across, when a woman who went for anti-wrinkle injections was suspected to have been given an unlicensed product and suffered dire complications.

“People think I’m exaggerating when I say this but she has literally had to have half her face removed,” Collins said. The woman is said to have suffered deep-seated infections that had “eaten away at her tissue and nerves”, leading her to require multiple surgeries.

The Times this week found multiple examples of unlicensed botulinum toxin products being marketed online. One Kent-based company, Exclusive Pharmacy, is openly advertising Botulax, a product that is legal in some countries but illegal for use in the UK.

Reviews on its social media page include one saying: “I have been using Botulax for two years now and I literally would not use anything else. Most clients don’t need [top-ups] and the price is great. I can afford to undercut the other clinics in my area.” Another wrote: “After years of using Bocouture and Azzalure [licenced botulinum toxin brands], paying prescription costs and getting mediocre results, all I can say is I’m gutted I didn’t discover Botulax sooner.”

Other companies, while not advertising unlicensed products, are offering rock-bottom prices of as little as £50 for enough Botox to treat three areas. This is significantly less than the raw cost of any licenced product, casting doubt over what may be being used.

Licensed versions of botulinum toxin injections are still being advertised on social media and as they are prescription-only drugs, this is in breach of advertising rules. These adverts include a practitioner offering “10 per cent off” treatments, while another company markets a designated day when Botox costs a certain price, urging customers not to “miss out”. One practitioner this week posted an Easter raffle with prizes including “three areas of Botox”.

Carolyn Harris, Labour’s co-chair of the all-party parliamentary group on beauty and wellbeing, called for the swift action from the government. “If it’s not properly governed, if we don’t give people the right training, if we don’t give proper accreditation and licensing to people who are properly qualified, then it’s potentially life-threatening”, she said. “Currently it’s the wild west and will continue to be the wild west.”

A Department for Health and Social Care spokesperson said: “We have already taken action to prevent under-18s from accessing Botox and filler treatments for cosmetic purposes, and we are now taking forward work to introduce a licensing scheme for non-surgical cosmetic procedures in England. This will make it an offence for anyone to carry out specified non-surgical procedures without a licence.

“This is a complex area and requires in-depth and extensive engagement with industry experts and the public. Following a series of positive discussions with stakeholders, we plan to carry out our first consultation on the procedures that will be in scope of the licensing scheme this summer.”


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