UK's New Cosmetic Procedures Consultation Revives a Three-Year-Old Promise

The Department of Health and Social Care has opened a consultation on draft regulations for what it calls "high risk" cosmetic procedures, including liquid Brazilian butt lifts, chemical peels and vampire facials, moving toward a licensing scheme first floated three years ago and still not in force.

The new document sorts procedures by a traffic light model built on proposals detailed in August. Red tier treatments, among them BBL-style fat injections, certain dermal fillers and hair restoration surgery, would be restricted to practitioners working within CQC-regulated settings. Amber tier treatments, such as Botox and semi-permanent fillers, could still be delivered by non-healthcare staff, but only under the named supervision of a regulated professional. The split determines who in the existing 5,500-plus clinic market, where UCL researchers have found only about a third of practitioners are qualified doctors, keeps the right to inject or operate without new sign-off.

The timing matters as much as the content. DHSC ran its first consultation on licensing non-surgical procedures in September 2023 under powers granted by the Health and Care Act 2022, proposing a two-tier practitioner and premises licence administered by local authorities. No regulations followed. In February, the Women and Equalities Committee's Eleventh Report of this Parliament went further, telling ministers to skip further consultation altogether and ban liquid BBLs and other "high harm" procedures immediately, while still giving the government this Parliament to build a licensing system for lower-risk treatments. Health minister Karin Smyth told the committee in June that draft regulations for the highest-risk procedures would come first, with licensing to follow. This consultation is that promised document, arriving two months after a coalition of royal colleges wrote to Health Secretary Yvette Cooper warning that the scheme had already slipped past its expected timetable.

What the consultation does not settle is who qualifies to perform the procedures it puts in the red tier. The Royal College of Surgeons of Edinburgh said in an August statement that any doctor registered with the General Medical Council can legally carry out cosmetic surgery in the UK regardless of specialist training, and called for high-risk surgical work to be restricted to surgeons on the GMC's Specialist Register. That request sits alongside, rather than inside, the licensing consultation, and whether DHSC folds it in will determine if the new rules close the qualification gap that campaigners have flagged since well before Alice Webb, a 33-year-old mother of five from Gloucestershire, died in September 2024 after a liquid BBL, a case cited repeatedly in Parliament as the clearest argument for a ban.

Enforcement has had less attention than the clinical categories. Any licensing scheme modeled on the 2023 proposal would put administration in the hands of local authority trading standards and environmental health teams, the same services already stretched by other statutory duties, and DHSC has not yet published figures on how enforcement would be funded. Save Face, the government-approved accreditation register, recorded roughly 3,000 complaints about botched treatments in a single year, 2022, the number originally cited to justify regulating the sector. Three years and one more consultation later, that backlog of complaints is the baseline the new rules will be measured against.