15th January 2024

Under the skin of illicit practices

Illicit cosmetic procedures can disfigure faces and ruin lives. New legislation goes some way to address the problem — but significant hurdles remain.

By Richard Young
You can see how quickly this starts to spiral. A teenager could spend £99 on a lip filler and then it turns into an absolute nightmare

Following the introduction of the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021, it is an offence for businesses in England to administer Botox or dermal fillers to people under the age of 18.1 The legislation was introduced amid concerns about the physical and psychological harm such procedures can cause to young people who fall prey to unscrupulous, unregistered and often elusive businesses.

The legislation places new responsibilities on Trading Standards to clamp down on illicit practitioners — who often operate via social media — and is supported by a combined £1.4m in annual funding which local authorities can access through the Department for Health and Social Care.

Ashton Collins is Director of Save Face, a government-approved register of accredited practitioners who carry out non-surgical cosmetic treatments. Her organisation was among those who lobbied for the legislation to be introduced, and through its network of registered clinics provides support to those who have been harmed by procedures gone wrong.

“The main problem is with fillers,” she says. “In the entire time that we’ve been gathering patient-reported complaints, we’ve only had two or three complaints relating to Botox treatments of under-18s, whereas for dermal fillers it’s much higher — into the hundreds. The risks involved are great, both in terms of mental and physical impact.

“Consequences of dermal fillers going wrong can include blindness, permanent tissue death, infections, lumps, bumps, nodules and other unsightly outcomes. These can be very distressing for anybody, but especially for a child who has gone into this thinking these are no-risk beauty treatments — because that’s how trivialised they are amongst that age group — and they’re going to look like whichever reality TV star or influencer they look up to.

“We’ve seen a lot of vascular occlusions, and they are really serious. When the dermal filler has been injected poorly, it can compromise the blood supply, and it blocks the blood vessel. When that happens, the filler needs to be dissolved quickly in order for the blood supply to return.”

Taking the initiative
One of the Trading Standards services taking steps to address the problem is operated by the Bracknell Forest and West Berkshire Public Protection Partnership. In the summer of 2023 Officers conducted a series of tests to ensure that local businesses were aware of, and complying with, the law. Senior Trading Standards Officer Heather Fleming explains: “It was a fairly new area to us — obviously historically we’ve done underage sales, so this fits in alongside that. We wanted to get a picture of what was out there — we were doing it as potential enforcement but mainly intelligence gathering.”

Fleming and her team called up 37 local businesses and arranged to make bookings for their ‘daughter’, requesting that the appointments be out of school hours. “The point was for the business to ask how old are they, what’s their date of birth?” Fleming says. “It’s an offence to book an appointment as well as being an offence to actually do the procedure. We adopted a light approach and in the end, we only had three business who were prepared to book an appointment without question or any further request for information. We then wrote a letter to all of the businesses providing links to the Business Companion website guidance, as well as information about the legislation itself and a reminder that it is now in force.”

The businesses that failed the test purchases will receive visits and further checks that they are complying. As Collins points out however, many of the irresponsible practitioners across the country provide no business address, meaning that tracking them down in the event of a problem can be easier said than done — and enforcement letters are likely to be ignored even if they do find their target. “People who are willing to offer treatments to underage teens are, as you’d imagine, quite unscrupulous,” she says. “They’re not healthcare professionals, they’re often not insured, and they’re often mobile, so they don’t have fixed business addresses. When these poor girls reach out to them and say, ‘I’m in pain, my face is swollen or bruised,’ they’re told that it’s to be expected and should be fine in a week — obviously, that’s not the case. The girl becomes more and more distressed, and the more they try to reach out to the practitioner, in almost every case that we’ve managed, they block them.

“These young girls are then left to try and solve the issue with their parents who are furious because often they’ve had these treatments done without their knowledge or their consent, and they then have to navigate their way to find help. More often than not, they’re turned away from NHS services because they’re not familiar with these treatments, they don’t provide them themselves, and they don’t stock the drugs needed to reverse the effects.

“The victim then has to try and find another private practitioner, which again is challenging because they don’t want to treat a child. There are no clinical records, so they don’t know what filler has been used or where it’s been injected. You can see how quickly this starts to spiral. A teenager could spend £99 on a lip filler using their birthday or Saturday job money and then it turns into an absolute nightmare.”

Social pressure
Much of the damage caused by these illicit procedures originates on social media — either from the pressures of living up to unrealistic beauty standards that many teenage girls are faced with, or from direct advertising by the practitioners themselves. “It’s a hotbed for unscrupulous practice, both for under-18s and in general,” says Collins. “We’ve been going since 2014 and in that time, we’ve helped over 15,000 members of the public who’ve fallen into the hands of unsafe practitioners, over 80% of which are non-healthcare providers that operate only on social media. They often use illegitimate products purchased from places like China or India because they’re cheap, and they don’t have to have prescriptions for them. There are hundreds of these operators at large in the UK.”

To get a better grip on the problem, Fleming advises Trading Standards teams to work with their Environmental Health and Public Health colleagues, who may have records of local practitioners. “Environmental Health licenses and checks up on businesses that provide things like acupuncture, skin piercing and tattoos, some of which also provide these cosmetic procedures,” she says. “And be aware that there’s specific enforcement funding available through the Public Health route.”

It is clear though that much still needs to be done to address the problem, both from a practical enforcement point of view and in terms of tighter regulation. As Collins says, “Because this law only applies to England, some people will hop across the border to Scotland or Wales for these procedures. Unfortunately though, in many instances, there is no need for them to even travel because people are still operating illegally in their area.

“The legislation clearly states that it is the responsibility of businesses to age check everybody — that needs to be far more embedded into their practices. But because they’re unregulated and they operate like ghosts with no fixed address — for Trading Standards, how do you even contact them?”

1. Registered medical practitioners with appropriate training may still administer cosmetic fillers or botulinum toxin to patients aged under 18 as part of a necessary medical treatment.

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