The Regulation of Non-Surgical Cosmetic Procedures
| Author | Sophie Cole |
| Position | LLB (Soton) |
| Pages | 37-49 |
(2021)
Vol. 11
37
The Regulation of Non-Surgical Cosmetic Procedures
Sophie Cole
*
Abstract
The growth of non-surgical cosmetic procedures has brought with it concerns over the regulation of the industry.
Procedures such as dermal fillers and botox injections are becoming increasingly popular. Yet despite the risks
involved in these procedures, such as infection and scarring, there is a worrying lack of legislation governing the
sector. Dermal fillers, for example, can be administered by anyone, with no training required.
This law reform project therefore proposes the introduction of a comprehensive statute to greater control the
products, premises and practitioners involved in the administration of non-surgical cosmetics. The project will
assess the current legislation, and the lack of it, before considering a new statute and the positive impact this
could have.
Introduction
he purpose of this Law Reform Project is to propose the introduction of greater
regulation of non-surgical cosmetic procedures in the UK. The current lack of
legislation in this area means that patients are left vulnerable to exploitation. It will
therefore be suggested that a statute should be introduced to regulate the products, premises
and people who can administer such procedures.
‘Non-surgical cosmetic procedures’ include a variety of treatments. The most important ones
for the purpose of this proposal are botulinum toxin (botox henceforth) and dermal filler
injections. Other examples include chemical peels, laser treatment and hair restoration
surgery.
The cosmetic industry has continued to grow in recent years. Virtually all cosmetic
interventions occur in the private sector. Whilst the whole industry, including surgical and
non-surgical options, was estimated to be worth £2.3 billion in 2010,
1
a recent report suggests
that non-surgical procedures alone will soon be worth £3 billion.
2
Accounting for 9 out of 10
cosmetic interventions, and approximately 75% of the total market value, non-surgical
options are by far the most popular in the market.
3
The growth of these treatments can be attributed, in part, to the increasing use of social media
and how body image is portrayed online. Media coverage of celebrities’ procedures and the
increasing availability of treatments has created ‘a climate in which having a cosmetic
procedure is increasingly regarded as normal and the associated risks are often
underestimated’.
4
*
LLB
(Soton).
1
‘Cosmetic Surgery Market Intelligence’ (Mintel, 2010) <https://reports.mintel.com/display/480789/#>
accessed 11 April 2020.
2
‘Cosmetic Surgery UK Market Review’ (LaingBuisson, 2019) <https://www.laingbuisson.com/wp-
content/uploads/2019/09/Cosmetic_Surgery_1ed_SALES_FLYER.pdf> accessed 10 April 2020.
3
Review of the Regulation of Cosmetic Interventions
(Department of Health 2013) para 3.26 (Keogh Report).
4
‘Regulation of Cosmetic Interventions: Research among the General public Practitioners’ (Creative Research,
28 March 2013)
T
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