Product regulation
As regulation looks set to tighten around who can practise aesthetic medicine and how, increasing scrutiny is also being placed on the products being used to provide treatments.
In this chapter, we explore the current product safety landscape, recent alerts from UK authorities, and what you can do to stay compliant and protected under current legal frameworks and guidelines.
From unlicensed injectables and grey market fillers to counterfeit packaging and untraceable toxins, the issue of product regulation is coming as much to the forefront as the issue of who carries out aesthetic treatments and where.
Whether you're a prescriber, practitioner, or clinic owner, understanding your responsibilities when it comes to product safety is critical.
Not only does this protect your patients and your reputation, but it also keeps you compliant with trading laws, professional standards, and insurance requirements.
In June 2025, The Chartered Trading Standards Institute (CTSI) issued an urgent warning over unregulated aesthetic procedures, saying it believed “vulnerable consumers are increasingly exposed to unsafe practices and products that pose a risk to their health and safety.”
The release highlighted a growing number of issues, including major gaps in regulation with a lack of clarity on who is responsible for the products and procedures and called for tighter regulation including removal of unsafe products sold online.
“Trading Standards have warned that in most cases the products and services in the aesthetics injectable sector are unregulated”, commented Richard Knight, CTSI Lead Officer for Cosmetics and Beauty. “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.”
Hamilton Fraser supports the CTSI viewpoint and urges practitioners to conduct due diligence on all suppliers and manufacturers. Failure to do so could result in prosecution, insurance invalidation, or reputational harm.
For new practitioners, navigating suppliers can feel daunting. While we explore specific tools and resources later in this chapter — including MHRA reporting services and patient education guides — it’s important to note up front that there are trusted, authorised UK distributors. Sourcing through these official channels not only protects patients but also ensures your insurance remains valid. There’s more on how to do this later in the chapter.
Counterfeit products are imitations of licensed brands, often sold online or via unofficial distributors, with falsified packaging, safety data, or batch codes.
According to reports, over 41% of practitioners have encountered counterfeit aesthetic products, with nearly 40% reporting adverse events among patients exposed to them. These most often include fake botulinum toxins and dermal filler products.
The growing popularity of weight loss injections, including GLP-1 agonists, has also spurred a black market of dangerous counterfeit products. The MHRA in the UK seized batches of counterfeit pens falsely labelled as Ozempic in 2023, and took down 150 social media posts “actively” selling counterfeit weight loss drugs in 2024.
An article by Safety in Beauty founder Antonia Mariconda for Aesthetic Medicine, highlights the depth of the problem, pointing out how criminals exploit the aesthetics boom by creating sophisticated replicas that often pass as genuine products until it’s too late.
Unlike counterfeit products, grey market products are often genuine products obtained through unofficial or unauthorised channels. These can include overseas wholesalers, discounted online retailers, or bulk suppliers with no UK regulatory compliance.
Both pose serious risks including:
Contamination or sterility issues from improper storage or transport
Adverse reactions due to expired or tampered ingredients
No recourse if a product causes harm — as manufacturers will not honour warranties or liability if the product was purchased through an unauthorised route
Insurance exclusions — if you use an unlicensed or grey market product, you may not be covered under your policy.
Red flags for grey market or counterfeit products:
Extremely low pricing
Absence of UKCA or CE markings (for medical devices)
Poor-quality packaging or spelling errors
Lack of English-language instructions or packaging
No MHRA registration or UK product licence (for medicines)
Missing batch numbers or falsified expiry dates
Sellers who cannot provide origin documentation
Practitioners are urged to purchase only from authorised UK distributors, retain documentation for every product, and educate patients on how to identify legitimate treatments. Never be tempted by cheaper online deals or bulk orders from unverified suppliers. If in doubt, don’t use it — and report it.
If you're using grey market toxins, fillers, or injectables, you may unknowingly place patients at risk and expose yourself to legal consequences. As Hamilton Fraser’s advice makes clear, if a product causes harm and cannot be traced or verified, you may not be covered — regardless of your clinical skill or training.
Between June and July 2025, the UK Health Security Agency (UKHSA) confirmed 38 cases of iatrogenic botulism, linked to counterfeit or unlicensed botulinum toxin injections administered in non-clinical settings.
This unprecedented outbreak saw six patients requiring critical care due to respiratory paralysis. The incident exposed the risk behind rogue products and unqualified injectors — prompting the rapid release of a patient education guide, The Invisible Risk Behind Unregulated Botulinum Toxin (Botox Like) Treatments – authored by award-winning nurse Julie Scott and supported by the JCCP.
Although designed primarily as a patient-facing education tool, the guide is also a valuable resource for practitioners, offering a safety checklist and reporting advice that clinics can integrate into their own protocols.
The guide provides:
A safety checklist for verifying prescribers and products
Guidance on MHRA licensing
Red flag symptoms of botulism
Steps for reporting adverse events
Scott warns, “Counterfeit toxins bypass every safeguard we have — licensing, sterility, traceability — and pose a silent but serious threat to public health.”
The case reinforced the importance of:
Using licensed prescribers to obtain and administer prescription-only toxins
Only using MHRA-approved products supplied through authorised UK channels
Reporting any adverse events or concerns about suspicious products to the MHRA Yellow Card scheme
In August 2025, the Medicines and Healthcare products Regulatory Agency announced two important online services to help combat the illegal sale of medicines:
The ‘not recommended’ list – A searchable database of scam websites known to sell medicines illegally.
The reporting tool – An easy-to-use form to report suspicious online sellers of medicines or medical devices.
These tools are designed to empower people considering purchasing medicines online by:
Providing clear guidance on ‘red flags’ to look for
Directing users to trusted, verified sources of information
You can access the new services here:
MHRA contact page
Check the ‘Not Recommended’ list
Report a suspicious seller
How do you find a trusted UK distributor?
Finding a safe and reputable distributor is one of the most important steps in protecting your patients and making sure your insurance remains valid. Here are some ways to identify and verify a trusted UK distributor:
Only purchase products through regulated UK suppliers or pharmacies. Ask for batch numbers, MHRA licences, and cold chain documentation.
For medicines (e.g. botulinum toxin, prescription-only injectables), the distributor must be licensed by the Medicines and Healthcare products Regulatory Agency (MHRA). You can search the MHRA’s database of licensed wholesalers.
For medical devices (e.g. dermal fillers, lasers), look for a CE mark (for products registered before 2021) or a UKCA mark (for products registered after Brexit).
Many prescribers and clinics source products through established UK pharmacies that are regulated and routinely inspected. These suppliers can provide full documentation including batch numbers and cold-chain records. Go to the General Pharmaceutical Council website to check their register.
Networking at conferences, exhibitions and CPD events is also a useful way to learn which distributors are trusted by experienced practitioners.
If a supplier refuses to provide documentation, batch codes, or safety data — walk away. Patient safety and legal compliance must always come first.
Here are some other steps you can take to keep yourself safe when it comes to products:
Make sure all products are traceable, approved for UK use, and sourced from a regulated supplier. Maintain detailed product records, including:
Supplier invoices
Storage logs
Expiry dates and serial numbers
Prescriber information (for POMs)
Look for UKCA or CE marks for devices and MHRA licenses for medicines. Check for intact seals, and correct English-language instructions. Be wary of international products with no UK registration.
Make sure all staff, including front-of-house, understand the difference between licensed and unlicensed products and the importance of sourcing from the right channels.
Your insurance must reflect your products and procedures. Always check whether your insurer covers adverse events linked to product origin or batch issues. Hamilton Fraser, for example, will only provide cover for approved and appropriately sourced products.
Use the MHRA’s Yellow Card Scheme to report counterfeit or adverse reactions. This helps authorities track dangerous trends and issue warnings more effectively.
It’s also worth noting that not all products used in aesthetics fall under MHRA scope. For example, cosmetic creams, serums, and devices may instead fall under the remit of the Office for Product Safety and Standards (OPSS). Practitioners should familiarise themselves with OPSS guidance and report concerns about non-medical products directly via the OPSS website.
For experienced practitioners, many of these steps may be familiar. But for those newer to the sector, following this checklist can provide a clear roadmap to safe sourcing and regulatory compliance.
As regulation increases across the aesthetics industry, the product supply chain will be one of the most closely watched areas. Expect tougher scrutiny from Trading Standards, greater MHRA oversight, and potential licensing conditions requiring clinics to prove the provenance of their stock.
Practitioners who take the lead in sourcing ethically, documenting carefully, and educating their teams will not only protect themselves and their patients — they’ll also demonstrate leadership and professionalism in a maturing industry.
The products you use say as much about your practice as the treatments you offer. Make sure they stand up to inspection.
If you’re using products that haven’t come through regulated UK supply chains you could be operating outside the law and putting patients at risk. Your reputation, your licence, and your patients’ health all depend on the products you choose. Make that choice wisely.
