A recent survey found that one-third of Scottish doctors have treated patients with complications from cosmetic procedures, with the youngest reported case involving a 16-year-old. These findings have renewed discussions about the regulation of facial fillers and injectables in Scotland, as these treatments remain widely accessible despite potential health risks.
Currently, there are no legal requirements in Scotland for medical qualifications to administer these treatments, nor are there restrictions on under-18s receiving such treatments. This has created a landscape where procedures can be performed by individuals without formal oversight, using products that may vary in quality, risk and safety.
In December 2024, the Scottish Government launched a public consultation aimed at introducing a structured framework for regulating cosmetic treatments. The proposed system categorises procedures based on the level of risk posed to the patient. Low-risk treatments that do not require medical expertise fall into the first category and can continue to be performed without any formal qualifications.
The second category covers procedures that require supervision by a medical professional, ensuring that a trained individual oversees the process. The third and highest-risk category is reserved for procedures that must only be performed by qualified medical practitioners, ensuring that invasive or complex treatments are carried out with the necessary expertise and safety precautions.
Healthcare professionals, including Healthcare Improvement Scotland (HIS), have highlighted that cosmetic injectables are widely regarded as high-risk procedures and, as such, should be classified within the third category. When administered by unqualified practitioners, these treatments can lead to serious complications, including infections, scarring and even permanent vision loss, underscoring the need for greater oversight and patient protection.
Experts warn that even 0.1ml injected incorrectly can lead to severe complications, underscoring the need for evidence-based volume regulations. Instead of focusing solely on limiting the amount of filler used, many in the industry believe regulation should prioritise practitioner expertise, safety protocols and product quality.
In response, a group of leading Scottish medical professionals has written to the Minister for Public Health and Women’s Health, urging the Government to reclassify facial fillers as a high-risk procedure requiring strict medical supervision. Their argument is clear: allowing untrained individuals to perform these procedures is a serious public health risk that requires immediate action.
Jurisdictional differences may be instructive. England has tightened its regulatory framework, while Scotland is in the process of reviewing its approach. This has led to discussion about whether these differences could result in individuals, including under-18s from England, seeking procedures in Scotland that are subject to different requirements. This highlights the contrast in UK regulations and how Scotland compares to other European countries, where cosmetic treatments are often subject to stricter controls.
As the Scottish Government's consultation concludes later this month, its response to healthcare experts' recommendations will become clearer. Effective regulation of facial fillers is not only essential for public health protection but also for maintaining ethical and safety standards in Scotland’s growing cosmetic industry.
Without tighter regulation, enforcement, and practitioner accountability, Scotland may risk becoming a hub for unregulated cosmetic procedures - at the cost of patient safety.
This article was originally published in the Scotsman - read more here.
