By Dr Aamer Khan, Cosmetic Doctor and Former GP
The UK aesthetics industry is booming, yet dangerously under regulated. As a former GP and cosmetic doctor with over three decades of clinical experience, I have watched with increasing concern as the field I once championed for its innovation and transformative outcomes becomes a magnet for unsafe practices, non-medical injectors, and a flood of poorly controlled or unlicensed products.
One of the most alarming developments is the rapid rise in use of Innotox – a liquid botulinum toxin that is not licensed for use in the UK. While this product offers some practical benefits in trained hands, its widespread use by non-prescribers and unregulated injectors is a symptom of a much wider issue: an industry operating in a regulatory vacuum.
A Growing Industry – and Growing Risk
The UK non-surgical aesthetics market is reportedly worth over £3 billion, with injectables such as Botox and dermal fillers making up around 80% of that market. And yet, shockingly, no mandatory regulation currently exists to stop a non-medical individual from injecting fillers – or even acquiring unlicensed botulinum toxins.
A 2023 report from the All-Party Parliamentary Group on Beauty, Aesthetics and Wellbeing found that over 70% of complications following aesthetic treatments came from procedures performed by non-healthcare professionals. Lack of standardised training and misleading advertising were major contributors to patient harm. Clinics are regularly sourcing unlicensed injectable products online, including Innotox, without adequate quality assurance.
Despite repeated warnings from regulatory bodies, we still see cases of necrosis, infection, nerve damage, and psychological trauma from improperly administered injectables, many of which could be avoided with appropriate training, regulation, and oversight.
What is Innotox, and Why is it a Concern?
Innotox, developed in South Korea, is a ready-to-use, liquid form of botulinum toxin that boasts greater stability and convenience compared to traditional powdered versions like Botox. It’s widely used across Asia and Latin America, but it has not been approved by the UK’s Medicines and Healthcare products Regulatory Agency (MHRA) or the US FDA.
Unlike Botox and other UK-licensed toxins, Innotox uses a different measurement system (units are not interchangeable with Botox or Dysport). It is prescription-only in countries where it is licensed. Side effects and long-term safety data are less established due to fewer peer-reviewed studies.
Despite these concerns, Innotox is being imported illegally into the UK via grey-market suppliers and used by individuals with no prescribing rights, medical training, or insurance cover.
The problem isn’t just the product, it’s the entire culture of under-regulation that allows untrained injectors to carry out complex procedures with no regard for safety or accountability.
The Public Think it’s Already Regulated – It’s Not
Polling by the British Beauty Council and Save Face has shown that 84% of consumers wrongly assume the aesthetics industry is already regulated. Many assume that if someone is offering Botox or filler injections, they must be medically qualified. But this simply isn’t the case.
While Botox is classed as a prescription-only medicine, dermal fillers are still only regarded as medical devices, which means anyone can legally buy and inject fillers, regardless of training or qualifications. There is no mandatory register for practitioners. Complaints often go unresolved unless serious harm occurs.
In 2022, it was reported that there were over 2,824 complaints about botched procedures – 81% of which involved unregistered practitioners, and 89% of which took place in unregulated settings like homes, salons, or pop-ups.
Change Is (Slowly) Coming – But is it Enough?
The government has committed to implementing a licensing scheme for non-surgical cosmetic procedures under the Health and Care Act 2022. A public consultation on the scope of that scheme closed in late 2023, with much-needed legislation expected in 2026 – 2027.
But we must ensure this scheme is mandatory, not voluntary. It must be backed by enforceable standards of training, insurance, and product use. It must be clear on who can prescribe and administer prescription-only medicines. It must be transparent for the public, including a national register of licensed injectors and clinics.
Immediate Reform is Needed
This is not about gatekeeping the industry, it’s about safeguarding patients and restoring trust. Aesthetic medicine can be life-enhancing, both psychologically and physically, but only when delivered by qualified professionals who understand facial anatomy, pharmacology, and how to manage complications.
At Harley Street Skin Clinic and Ballingdon Hall Wellness Retreat, patient safety and ethical care have always been our core values. But as I meet more and more patients seeking corrective treatments for procedures gone wrong elsewhere, I am reminded that the entire system is failing those it should protect.
Until regulation becomes reality, I urge patients to check that their practitioner is a GMC, NMC, GDC, or HCPC-registered professional. Ensure prescription-only treatments are prescribed by a qualified prescriber after a face-to-face consultation. Avoid unlicensed products, including Innotox, unless approved and prescribed under medical supervision.
Let’s bring aesthetic medicine back into the hands of those qualified to deliver it. Let’s protect the public and raise standards for all because looking good should never come at the expense of safety.
