Calls grow for UK government to accelerate Botox crackdown

Jacqueline Harris and Louise Fullwood of Pinsent Masons were commenting as the UK government faces mounting pressure to fulfil its pledge to regulate non-surgical cosmetic procedures (NSCPs) – including ‘Brazilian butt lifts’, Botox and dermal fillers – that have left people maimed, injured and requiring hospital treatment.

In August 2025, the government proposed tough new measures to bring these types of aesthetic procedures under a new regulatory framework to “bolster patient safety”. This was in recognition that the current framework placed too few restrictions on who can perform non-surgical cosmetic procedures and what qualifications, training and infection control measures they had undertaken.

These proposals include placing cosmetic procedures in three risk categories – ‘red’, ‘amber’ or ‘green’ – according to their complexity, invasiveness and the potential for complications.

Procedures like Brazilian butt lifts, fillers and hair restoration surgery would be categorised as ‘red’ procedures and assessed to carry the highest level of risk. This would mean that they could only be carried out by qualified and regulated healthcare professionals working in services that are registered with, inspected and regulated by the Care Quality Commission (CQC).

The government proposed that procedures such as Botox and prescription-only weight loss injections used for cosmetic purposes would be categorised as medium risk, ‘amber’ treatments. These could be performed independently by qualified healthcare professionals that meet certain standards. There was also a proposal to allow non-healthcare practitioners to carry out these procedures if they were under the oversight of a named regulated healthcare professional. Meanwhile, ‘green’ procedures, such as semi-permanent make-up and non-ablative laser hair removal, would be deemed low risk, and could be carried out by licensed practitioners that meet “agreed standards”.

The government pledged to restrict cosmetic procedures such as Brazilian butt lifts to over 18s in England “unless authorised by a healthcare professional”. It also announced plans to introduce a new licensing scheme in England authorised by local authorities for lower-risk cosmetic treatments to ensure public safety. However, there remains concerns about how such a scheme could be managed effectively without risking duplication of oversight and fee requirements for businesses.

The government said it would consult more widely on introducing regulations for the highest risk procedures early in 2026, but there has been no further progress to date.

However, pressure is mounting to regulate this corner of the cosmetics industry. In December 2025, the British Association of Aesthetic Plastic Surgeons (BAAPS) published a statement saying it was “imperative” that the government took immediate action to regulate liquid Brazilian butt lifts in light of growing concerns over the risks the procedure posed to patient safety.

Earlier this month the House of Commons’ Women and Equalities Committee said in a parliamentary report that such high-risk procedures should be “banned immediately without further consultation” and reiterated calls for the government to introduce a licensing system for low-risk procedures. The committee’s chair, Labour MP Sarah Owen, said the government’s intention to carry out “yet another consultation” would only “cause more delays” and risked “compromising patient safety.”

This criticism prompted the Chartered Institute of Environmental Health to issue a statement calling on the government to publish a definitive timeline for implementing its proposed licensing scheme in England.

These calls come as progress on this issue continues to accelerate in Scotland. Earlier this month, the Scottish parliament’s Health, Social Care and Sport Committee approved in principle the provisions of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill, which will now proceed to detailed consideration of its provisions. 

Although similar to the government’s proposed system in England, the Scottish position adopts a two-rather than three-tiered approach to regulation, with high-risk procedures allowed to take place only in permitted premises and under the supervision of authorised medical practitioners. Meanwhile, lower-risk procedures will be regulated through secondary legislation under the Civic Government (Scotland) Act 1982.

However, the bill still has several hurdles to overcome before it becomes law and significant concerns have already been raised around clarity, enforcement and penalties for offences committed under the proposed legislation. Wales and Northern Ireland have yet to announce similar plans.

Commenting on these developments, Harris, a product liability and litigation expert at Pinsent Masons, said “both the Scottish Health, Social Care and Sport Committee and the House of Commons’ report recognised the need for the devolved nations to work together on this issue to achieve proper protection for consumers”. She added that a lack of regulatory alignment across the UK would “create significant risks, including inconsistent safety standards and the potential for ‘cosmetic tourism’ within the UK, where individuals seek treatments in jurisdictions with weaker protections”.

Fullwood, a medical law expert at Pinsent Masons, said this alignment would be critical for consumer protection, but that enforcement would also be “essential” to keep ‘rogue’ actors at bay. “For an effective regime, enforcement needs to be well considered and properly resourced so that bad actors in the area understand that they will face serious consequences for compliance failures and legitimate business are not penalised for ensuring safety,” she said.