“We have an inclusive philosophy to economic activity where government tries to find the balance between public safety while maintaining an innovative and effective economy,” he said.
In 2023, when the government consulted on a licensing scheme for England, some respondents warned that any new regulation would need to be proportionate. While there was broad support for improving safety, concerns were raised about the potential impact on small businesses, which make up much of the sector, and the risk that overly restrictive rules could limit consumer choice or drive parts of the industry underground.
But the current situation across the UK can make it difficult for consumers to assess qualifications, understand what training a practitioner has received and know where to turn when treatments go wrong, says Zargaran.
“If you are a medical professional, you will have gone through certain types of training, including the important principles of consent, carrying out procedures, follow-up and recognising complications,” he adds.
More than a decade ago, the government commissioned an independent review of the cosmetic interventions industry following the PIP breast implant scandal, which saw thousands of women receive implants made with silicone that had not been approved for medical use.
The review, led by then-NHS Medical Director Professor Sir Bruce Keogh, examined the wider cosmetic sector, including dermal fillers, Botox and other non-surgical procedures.
It warned that people undergoing non-surgical cosmetic procedures had “no more protection and redress than someone buying a ballpoint pen or a toothbrush” and concluded: “It is our view that dermal fillers are a crisis waiting to happen.”
The review called for practitioner licensing, stronger training requirements and tighter controls over who should be allowed to perform cosmetic procedures.
Following the Keogh Review, the government introduced a system of voluntary self-regulation. Organisations such as the JCCP were established to set standards and encourage practitioners to join accredited registers.
But Rankin says this approach has not worked and many practitioners remain entirely outside voluntary schemes: “What was underestimated was the extent to which, in a self-regulatory framework, practitioners would not be interested in meeting those standards.”