Further consideration
The DHSC has acknowledged it will need to have further public consultations as many issues were raised in the initial consultation.1
For example, feedback has raised questions over whether an amber-tier is appropriate, necessary, or workable, asking which practitioners will be eligible to perform which level of procedures. These in turn may need to be classified in more than one category, depending on factors such as the procedure’s location on the body, the depth of penetration, or the equipment used.
Another amber category consideration will be around health professionals’ prescribing qualifications and implications for whether a particular cosmetic procedure falls within their professional scope of practice.
The DHSC will also decide whether there should be a blanket ban on procedures for those under 18 years, or whether there could be specific circumstances for teenagers or youngsters to have access to specified procedures. If the latter, these procedures would still most likely need to be carried out by or with the approval of a registered doctor.
One example of a cross-border difference noted by the DHSC is that under 18s in England could currently be circumventing age restrictions imposed by the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 by obtaining treatments in Wales.1,7
Several activities – tattooing, cosmetic piercing, electrolysis, semi-permanent skin colouring, and acupuncture –currently fall under the Local Government (Miscellaneous Provisions) Act 1982. The DHSC consultation noted the support to have these procedures included in the new licensing system under the green category.1,8