2 September 2023

Big shake up for the cosmetic treatments sector

The cosmetic treatments industry faces its biggest shake up in a generation according to the Joint Council for Cosmetic Practitioners (JCCP).  A major government consultation, launched today (Saturday 2 September) seeks the views of members of the public on a new licencing scheme for non-surgical cosmetic procedures such as botulinum toxin injections, chemical peels and dermal fillers.  Prof David Sines, Chair of the JCCP says, “This will dramatically improve consumer safety and reduce the risk of injury and harm arising from ‘botched’ and improperly performed  cosmetic treatments.”

The new licensing scheme will involve a practitioner licence and a premises licence and will make it an offence for anybody to carry out non-surgical cosmetic treatments without a license.  It will also make it illegal to treat anyone under the age of 18 with such treatments.

The scheme seeks to ensure that people who administer cosmetic procedures are properly experienced, trained and qualified, have the necessary insurance cover and operate from premises that are clean, hygienic and suitably licensed.  The scheme will be administered by local authorities across England.

The JCCP has worked closely with the Government and regulatory authorities in England to achieve legally enforceable governance arrangements for the cosmetic sector.  The Government’s new consultation document is the result of our long-term work and collaboration to co-design a new, sustainable system of regulation to protect members of the public.

Professor David Sines CBE, Chair of the Joint Council for Cosmetic Practitioners, said:

“In recent years we have seen a massive growth in the number and types of non-surgical cosmetic procedures.  Alongside this growth we have seen a dramatic increase in the number of complaints about substandard treatments, unregulated cosmetic products and unsuitable treatment premises”.

“All too often it is the NHS – and therefore the taxpayer – that has to pick up the pieces when a cosmetic procedure goes wrong.  The Joint Council for Cosmetic Practitioners has seen a 400% increase in complaints in the last year alone, so we warmly welcome this important step towards proper regulation.  Nothing is more important than public protection and patient safety.”

“The recent explosion in cosmetic procedures has been fuelled by social media, the proliferation of high street beauty outlets and a dramatic increase in the range of cosmetic procedures including those involving botulinum toxins such as Botox ©, dermal fillers, chemical peels, vitamin injections or infusions and laser treatments.  All these procedures carry the risk of serious harm if they are not administered by suitably trained professionals operating from clean and hygienic premises”.

“I warmly welcome the government’s decision to consult on this new, proposed licensing scheme.  It will help to ensure that people who undergo non-surgical cosmetic procedures receive treatment from practitioners who are properly trained and qualified, have the necessary insurance cover and operate from premises that are safe and hygienic”.

“I would urge everybody to seize the opportunity provided by this consultation and support the move towards sensible and proportionate regulation in this important sector.”

The JCCP has prepared a public guide to the Government consultation, with a clear explanation of what it means and how to respond to it. This can be found here. The JCCP’s FAQ guide also covers the scope of the proposed license, and answers questions related to practitioner related issues, education and training, age restrictions and key stages of the consultation. You can read the full FAQ guide here. 

New national survey looking at individual patient experiences of Botulinum Toxin Complications now launched

‘Collaboration between JCCP, BAAPS and University College London to identify extent of challenge faced by members of the public following the receipt of cosmetic injectable procedures’

The JCCP is committed to ensuring patient safety. In furtherance of this objective we are collaborating with researchers at University College London (UCL) and clinicians at the British Association of Aesthetic Plastic Surgeons (BAAPS) to contribute to building a scientific evidence base to inform safer evidence-based practice.

The strong research reputation and background of UCL is key to this collaboration and formalises a partnership extending several years, in addition to benefitting from the clinical expertise at BAAPS.

This novel survey has a primary aim of capturing individual consumer experiences following receipt of Botulinum Toxin injections. The survey was created with a cross disciplinary team including researchers, psychologists, clinicians, and patient representatives. If you have had a difficult or challenging experience that you wish to share, this survey will provide the platform for you to do so.

It is hoped that with this information, the types of difficulties that members of the public may have experienced could be better understood.

This is particularly timely, as the highly anticipated government public consultation on the design of a new licence for non-surgical cosmetic practice in England is set to be launched by the Department of Health and Social Care in Spring of this year. It is hoped that the data collected from this survey will inform the public consultation and assist the UK Government in its endeavour to introduce statutory regulation for the aesthetic and non-surgical cosmetic industry.

The survey can be accessed here: https://qualtrics.ucl.ac.uk/jfe/form/SV_0GqSdlnYsELM7b0

Dr David Zargaran, lead researcher at UCL said: “Collaborating with BAAPS and the JCCP will bring together expertise which can help to shape best practice, and as a first step, we are looking to capture the patient experience. Our previous research has already highlighted how important a robust evidence base is in ensuring patient safety. This project will build on our previous work, and I am looking forward to continuing to evaluate the true public health impact of the aesthetic injectables market.”

Prof. Ash Mosahebi, Professor of Plastic Surgery at UCL and chair of BAAPS Academy research council  said: “This collaboration is a great example of the direct translational impact of the research we strive to undertake at UCL, leveraging the expertise of the JCCP and BAAPS too. The aesthetic sector can significantly benefit from greater research to understand the potential risks to patients, and we hope that with this survey we can better understand the risks of the sector as a whole”.

Prof. David Sines CBE, the Chair of the JCCP said: “The JCCP is delighted to engage with BAAPS and the UCL research team as a partner in this collaborative research project. The JCCP is committed to encouraging the collection of objective empirical data to assist in the construction of a robust and reliable evidence base upon which responsive systems of clinical governance and national oversight can be based for the aesthetic sector in the UK. The JCCP is actively supporting and promoting this research study’.

July 2022

Prescription medicines and non-surgical cosmetic procedures.

July 2022

The recent news that retail giant John Lewis is to offer in-store, non-surgical cosmetic treatments, in partnership with the Cavendish Clinic, has once again brought to the fore the question of risk and benefit associated with such procedures.

To be clear, there are a number of top-quality clinics, like the Cavendish Clinic, which employ experienced consultant doctors and specialist aesthetic nurses with considerable experience and expertise in the field but there are far too many high street shops that offer treatments such as Botox, dermal fillers, skin peels and laser therapy without the necessary clinical expertise.

A major area of concern involves the drugs or medicines used in cosmetic procedures.

Many cosmetic procedures require the use of prescription only medicines (POMs) and such medicines all carry some degree of risk. That’s why they are “prescription only” and this means they must be prescribed by somebody who is properly qualified to prescribe them.

Botulinum toxin injections, commonly known as ‘anti-wrinkle’ injections or Botox*, always require a prescription. Treatments to dissolve dermal fillers use the prescription only medicine hyaluronidase and these too require prescriptions. Other examples include vitamins given by injection and local anaesthetic injections designed to reduce the pain associated with certain procedures.

All doctors and dentists providing cosmetic procedures are allowed to prescribe POMs. Nurses, physiotherapists, and pharmacists are also allowed to prescribe POMs but only if they have specialist training and the necessary additional qualifications to prescribe.

So, how can you be sure that the person prescribing your medicine and carrying out your cosmetic procedure has the necessary qualifications to do so?

You can easily check your practitioner’s registration online with their professional regulator. For doctors and dentists this is the General Medical Council or the General Dental Council. All doctors and dentists can prescribe, but for nurses (registered with the Nursing & Midwifery Council) and others (such as those persons registered with the Health Care Professions Council or with the General Pharmaceutical Council), any prescribing qualification will be shown against the practitioner’s registration entry.

A prescriber may prescribe the relevant medicine and then delegate the cosmetic procedure to a non-prescriber, but they must do so in accordance with the standards set down by their professional regulator. It is against the law for anyone to administer a prescription only medicine unless they are directed by a prescriber.

The Joint Council for Cosmetic Practitioners (JCCP) has been established to set standards in this field and to consider both the benefits and the risks associated with non-surgical, anti-ageing treatments and hair restoration surgery. In recent years we have witnessed a growing number of harmful complications arising from such treatments many of which have been the result of sub-standard treatment administered by inappropriately qualified and poorly trained practitioners.

We believe that, except in rare cases such as an emergency, there should always be a face-to-face consultation between the person receiving the procedure and the person prescribing the medicine, before any procedure is undertaken. This consultation should include a full assessment of any patient concerns and as assessment of the patient’s reasons and motivations for wanting the treatment.

The prescriber should provide the patient with a summary of the benefits and risks associated with the procedure so that all the alternatives can be considered. And if the prescriber is not carrying out the procedure personally, they are responsible for ensuring that the person performing the procedure is competent to do so. Patients should check with their prescriber that they have undertaken this assessment. In addition, patients should always be provided with aftercare instructions and a contact number in case of emergencies.

Any complication arising from a cosmetic treatment should be reported to the regulatory authority, the Medicines and Healthcare Regulatory Agency (MHRA). You can easily do this by searching online for the MHRA yellow card scheme.

The Joint Council for Cosmetic Practitioners has developed the following list of ‘red flags’ as a checklist to assist in decision making about cosmetic procedures:

  • Are you responding to an online ad for licenced brands of botulinum toxin and other prescription treatments? It is illegal to advertise prescription medicines and JCCP advises that you avoid responding to any such advertisements.
  • Are you being offered a consultation with the prescriber of your prescription only medicine? You should be offered such a consultation.
  • Are you being offered treatment on the same day as the consultation? You should be given a “cooling off” period.
  • Has your practitioner advised you that they intend to use an unlicensed medicine, particularly an unlicensed brand of botulinum toxin? If so, beware!
  • Has your practitioner suggested or provided any form of additional treatment that was not agreed with your prescriber? This should not happen.
  • Have you raised a concern or experienced a complication after the procedure and discovered that the prescriber is not responding, or your practitioner intervenes without contacting the prescriber?
  • Contact the relevant professional regulator (e.g., GMC, the GDC or NMC etc) about your concerns with the prescriber.
  • Contact the Medicines and Healthcare Products Regulatory Agency (MHRA) through their
  • Yellow Card scheme if you have experienced a suspected adverse event relating to a medicine or a medical device.
  • Contact Trading Standards if the harm relates to use with a cosmetic product.

* Botox is a brand name. Other commonly used brands of botulinum toxin include Bocouture and Azzalure.

May 2022

Joint Council for Cosmetic Practitioners (JCCP)

The Cosmetic Practice Standards Authority (CPSA)

The JCCP and the CPSA say:

  • There should be statutory regulation to ensure that only cosmetic practitioners who meet the required standards for safe and effective practice can practise legally.
  • There should be national, mandatory education and training standards for all practitioners.
  • High-risk treatments, such as injectable toxins, fillers, invasive lasers, vitamin infusions, threads and ‘deep’ peels should only be administered by suitably trained and qualified healthcare professionals.

The Joint Council for Cosmetic Practitioners (JCCP) is a UK national body that registers practitioners and approves education and training providers, in the fields of non-surgical cosmetic treatments and hair restoration surgery.

The JCCP exists to provide a source of information and guidance for patients and members of the public with the key remit of ensuring patient safety and enhancing public protection.

The JCCP is accredited by the Professional Standards Authority which is accountable to Parliament and which oversees the regulation of health and care professionals working in occupations that involve statutory regulation (for example, doctors, registered nurses, dentists, pharmacists and allied health professionals).  The Professional Standards Authority also accredits registers of health and care practitioners in those areas that are not yet regulated by law.  The JCCP operates an accredited register for practitioners in the fields of non-surgical cosmetic treatments and hair restoration surgery.

The JCCP is also a charity registered with the Charity Commission and governed by a Board of Trustees.  To become a not-for-profit charity JCCP has had to demonstrate that it is operating for ‘public benefit’ which in this case means ‘patient safety’ and ‘public protection’.  The JCCP operates across the UK in England, Scotland, Wales and Northern Ireland.

The JCCP and the Cosmetic Practice Standards Authority (CPSA) are sister organisations.  The CPSA is an expert group of clinical specialists, with patient/public representation, that prioritises experience, evidence and patient safety.

The CPSA sets the standards which anyone who wishes to perform non-surgical cosmetic treatments must meet, whatever professional background they are from.  Practitioners who meet these standards can join a register held by the JCCP.  Members of the public can select a practitioner from the register, knowing they meet the standards established by the CPSA.

The JCCP and the CPSA were both established in response to a review into cosmetic practice led by Professor Sir Bruce Keogh in 2013. This review followed in the wake of the PIP (Poly Implant Prosthèse) breast implant scandal.  The Keogh review also focussed on non-surgical cosmetic treatments and highlighted several areas of concern.

The non-surgical sector has expanded exponentially in recent years and the CPSA estimates that such procedures now account for 9 out of 10 of all cosmetic interventions, with the remainder being surgical.

The JCCP and CPSA have jointly developed a Code of Practice for practitioners who provide non-surgical cosmetic interventions.  Amongst other things it requires practitioners to promote safety and patient wellbeing, always seek consent, provide adequate information, consider patients’ psychological and emotional needs and have indemnity and liability insurance.

The JCCP has been established to set standards for and to consider both the benefits and the risks associated with non-surgical, anti-ageing treatments and hair restoration surgery.  The treatments that we currently include:

  • Botulinum toxin injections
  • Dermal fillers
  • Skin rejuvenation including micro needling and skin peels
  • Laser and light therapy
  • Hair restoration surgery

In recent years the JCCP has witnessed a growing number of harmful complications arising from such treatments many of which have been the result of sub-standard treatment administered by inappropriately qualified and poorly trained practitioners.  We are also seeing gross misrepresentation of the benefits of treatment, not least on social media and other online platforms.

At the heart of the problem is a serious lack of independent information and advice for the public and the simple fact that this is an area that requires statutory regulation.

The government has agreed to introduce a new system of licensing for England for non-surgical cosmetic procedures.

The JCCP warmly welcomes this latest development which takes the form of an amendment to the Health and Care Bill, tabled by the government.  It will give the Secretary of State for Health and Social Care the power to introduce a national licensing regime, the scope and details of which will be determined after a public consultation.

The new licensing regime is designed to safeguard people who access invasive cosmetic treatments and follows new legislation that was introduced last year making it illegal to administer dermal fillers and injectable toxin treatments to under 18s.  The licensing scheme will introduce consistent standards that individuals carrying out non-surgical cosmetic procedures will have to meet, as well as hygiene and safety standards for premises.

The government has described the amendment as the next step on the road to effective regulation of non-surgical cosmetic procedures (and hair restoration surgery) in England.

CPSA Chair, Mr. Alex Woollard: “As we now embark on the next hurdle in the quest to improve patient safety in this sector; we welcome the Government move regarding legislation. Work must now continue in earnest to ensure that the standards consulted upon and adopted protect the public to the level that they expect and deserve. The CPSA will avidly support this process, in any way that we are able, with the wealth of experience amongst our founding specialty associations.”

The new licensing regime complements and fits well with the JCCP’s ten-point plan of action which says we believe there should be:

  • Statutory regulation to ensure that only practitioners who meet the required standards for safe and effective practice can practise legally.
  • National, mandatory education and training standards for all practitioners in these fields.
  • Clear, transparent information from service providers on risks, benefits, costs, qualifications, and insurance.
  • A clear, legal definition of what constitutes a ‘medical’ procedure, a ‘medically-related’ service and a ‘cosmetic’ treatment.
  • Robust standards and regulation for the safe, ethical and professional prescribing of medications and preparations.
  • Tighter controls on advertising and social media posts to prevent the promotion of unsafe, unethical and exaggerated messaging about products, education, training and service provision.
  • A nationally agreed process for the reporting and analysis of complications and adverse incidents.
  • A legal requirement that all cosmetic non-surgical and hair restoration surgical practitioners should hold an appropriate level of medical indemnity insurance to provide a proper redress scheme for service users.
  • Nationally agreed standards for the licensing and regulation of premises and treatment procedures.
  • A campaign to raise public awareness of the benefits and risks associated with non-surgical treatments and hair restoration surgery.

The JCCP and the CPSA are calling for the statutory regulation of cosmetic treatments involving injectables, fillers, invasive lasers, ‘deep’ peels, threads, vitamin infusions and other invasive treatments and says these should only be administered by suitably trained and experienced regulated healthcare professionals.

Our call for statutory regulation followed the publication, in July 2021, of a report on aesthetic cosmetic procedures from the All-Party Parliamentary Group (APPG) on Beauty, Aesthetics and Wellbeing.  The APPG recommended a national licensing regime to be introduced across England along with certain minimum training and qualification standards for practitioners conducting aesthetic treatments, but it fell short of recommending statutory regulation.  The JCCP and the CPSA welcomed the APPG report and urged the government to act on the recommendations as quickly as possible but the JCCP and the CPSA said it was clear the government needed to go further.

Prof. David Sines CBE, the Chair of the JCCP said, “After a lengthy period of discussion with practitioners, consumers, patients, stakeholders and politicians we have concluded that in the interests of patient safety and public protection, high-risk and potentially harmful procedures, such as the insertion of dermal fillers or the injection of toxins should only be administered by appropriately trained healthcare professionals.”

In early 2022 the JCCP played a pivotal role in influencing Parliamentarians to support the amendment that the JCCP and others tabled in the Autumn of 2021 to the Health and Care Bill, which has now made its way through to the final stage in Parliament. The Government’s resultant health and Care Act will introduce a mandated licensing regime for the more invasive cosmetic treatments and make it an offence for someone to practise without a licence and to practise from unlicensed premises.

The JCCP receives an average of more than thirty complaints and ‘issues of concern’ each week regarding unsafe practice associated with treatments, medicines and the supply of aesthetic products and the training standards and qualifications that many practitioners present with.

The JCCP aims to protect the public by:

  • Applying strict standards for entry to the JCCP Register.
  • Only approving education and training providers that deliver programmes that meet the standards.
  • Maintaining a register of individuals who successfully complete those programmes and accreditation procedures.
  • Seeking to ensure that only safe and ethically sourced products, devices and medicines are used in the administration of aesthetic treatments.
  • Taking action if the standards are not met.
  • Establishing clear and simple procedures to enable the public to raise issues of concern about the professional practice of registrants.
  • Providing simple and easily accessible information to the public about non-surgical aesthetic treatments.

The JCCP has established a Board of Trustees under the Chairmanship of Professor David Sines, CBE.  Professor Sines chaired the Health Education England stakeholder consultation following the 2013 Keogh Review into patient safety.  He has been Chair of the JCCP Board of Trustees since January 2016.  Professor Mary Lovegrove OBE is Chair of the JCCP Education and Training Committee and Andrew Rankin is Chair of the Practitioner Register Committee.  Dr. Martyn King is the Council’s Vice Chair and Dr. Paul Charlson, along with Andrew Rankin, co-chairs the JCCP’s Clinical Advisory Group.  Sally Taber leads the Council’s Complaints Team. John Underwood chairs the Council’s Marketing and Communications Committee and Kirsty Benn-Harris chairs the JCCP Policy, Resources and IT Committee. Our patient and lay advocate is Dawn Knight.  All are Trustees of the JCCP.

The CPSA chairperson is Mr. Alex Woollard. He is supported by the following Trustees: Dr. Tamara Griffiths, representing the British Association of Dermatologists; Mr. Simon Withey, Representing the British Association of Aesthetic Plastic Surgeons; Mr. Ahmed Ali-Khan, representing the British Association of Plastic, Reconstructive and Aesthetic Surgeons (BAPRAS); Mr. Alexander Armstrong, a Plastic Surgery Consultant as an Ex-Officio Trustee; Leslie Ash as ‘Patient and Public’ representation and Mr. Mark Mikhail, a Plastic Surgery Registrar and CPSA Secretary.