Trading Standards: Urgent Regulation of Fat Injections, Fillers and Botox Needed

The Chartered Trading Standards Institute (CTSI) is calling for urgent regulation to clamp down on providers of aesthetic procedures such as fat injections, Brazilian Butt Lifts, botulinum toxin and fillers – warning the public that there is a Wild West of untrained, unlicensed and uninsured individuals who may be putting lives in danger.

Trading Standards officers have uncovered shocking locations where procedures such as fillers are being administered, including “pop-up” shops on high streets, cubicles in public toilets, and hotel rooms. These locations fall outside typical business premises and make taking action against unscrupulous businesses and practitioners much more difficult.

With the growing popularity of regulated medications such as Ozempic and Mounjaro, CTSI is also concerned about fat dissolving injections, such as Lemon Bottle, which have little to no regulatory oversight to ensure their safe use by the public. These injections do not fall under the remit of the Medicines and Healthcare products Regulatory Agency (MHRA).  

Other issues that have been uncovered by Trading Standards recently include:

• Unsafe and unregulated filler products readily available for sale online to everyday consumers for as little as £20
• A postcode lottery across the UK in the minimum ages at which such procedures can be carried out – with young people crossing the border to have procedures carried out
  Unlicensed premises and unqualified practitioners carrying out procedures
• No collation of NHS data that shows the burden placed on already overstretched services through dealing with infections and life-threatening complications
• Major gaps in regulation with a lack of clarity on who is responsible for the products and procedures

It is over a decade since the Government was warned about the need for control of the market in aesthetic procedures, but there remains a vacuum which has already put lives at risk . 

In September 2024 Alice Webb, a 33-year-old mother of five, died following a reported BBL treatment (non-surgical Brazilian butt lift). BBL is a treatment designed to make buttocks bigger, more rounded or lifted. It can be offered as a surgical or non-surgical procedure. Surgical BBLs involve inserting silicone-filled implants and/or removing fat from other parts of the body before injecting it into the buttocks. Non-surgical BBLs – like the one Alice is believed to have had – involve injecting dermal filler into the buttocks. The filler is often made up of hyaluronic acid and it is commonly used in facial filling treatments, including lip and cheek filler.

Following its annual conference, the CTSI is now leading a coalition of national charities, urging the Government to get a grip with these issues before more lives are put at risk.

CTSI is calling for:

• A licensing scheme to help regulate the sector (see pages 14-15)
• The establishment of a Ministerial led government Task Force to help regulate this sector
• Extension of underage legislation to Wales, Scotland and Northern Ireland
• Removal of unsafe products sold online

CTSI is warning the public to:

• Research your chosen practitioner and check their credentials
• Be wary of people advertising their services on social media platforms
• Do not buy products to use at home – this comes with huge risks to your health

Richard Knight, CTSI Lead Officer for Cosmetics and Beauty, said: “Trading Standards have warned that in most cases the products and services in the aesthetics injectable sector are unregulated. Because of the big gap between the lack of hard and fast safety rules, and consumer expectations of their protection under the law, we are gathering evidence of harms to the public as part of a joint initiative to urge law-makers to adopt a cross-Government approach to tackling this Wild West situation.”

Kerry Nicol, External Affairs Manager at CTSI, said: “I am genuinely shocked by the scale of potential harm facing the public due to the alarming lack of regulation in the aesthetic industry. Consumers’ lives are being put at risk every single day. What’s worse is that many of these unregulated practitioners are preying on people’s vulnerabilities and the pressures they feel around body image, they are taking advantage of those who are often just looking for a boost to their confidence or self-esteem. 

“Alarm bells would ring if someone was offering a tattoo in someone’s kitchen or a public toilet at a cheap price – so those are the alarm bells we need ringing for people offering facial injections in these kinds of settings. Action is urgently needed to crack down on the bad players operating in this sector. This isn’t an issue that Trading Standards alone can fix, it’s a Government and multi-agency responsibility that requires coordinated activity. 

“A logical and immediate first step is the introduction of a national licensing scheme, giving the public a clear indication of who is qualified to carry out these procedures. It’s time the UK takes public safety seriously and weed out those putting lives at risk.”

Ashton Collins, Director at Save Face, said: “We are delighted to join forces with CTSI on this campaign. Since 2023, we have been campaigning for the Government to ban liquid BBLs from the high street and restrict their administration to qualified plastic surgeons. We cautioned that without urgent action, lives would be at risk, and sadly, in 2024, Alice Webb tragically lost her life after undergoing a liquid BBL procedure. Alongside CTSI, we are determined to ensure our call to restrict liquid BBLs is acted upon. Additionally, we are focused on reinforcing existing legislation that has long failed to protect patients from unscrupulous practitioners who continue to flaunt the law with impunity. For too long, regulations intended to safeguard patients have been inadequately policed and enforced. Together, we aim to address the illegal importation of unlicensed products, remote prescriptions, and misleading advertising on social media. We strongly believe that by successfully implementing these measures, we can significantly improve industry standards and safeguard the public.”

Cheryl Barton RGN INP PGDip (CosMed), Lead Nurse at Aesthetika Clinic, said: “It is very important that any untoward or adverse effects, events or reactions from taking or receiving any medicines, injections or from treatments using medical devices are reported to MHRA via the Yellow Card Reporting System and Ring NHS 111 and/or seek medical assistance if required.”