The safe, ethical and legitimate sourcing of products

As the development of the cosmetic licensing scheme progresses, the JCCP continues to engage with stakeholders and with the Government to advise and inform the direction of travel. The JCCP Clinical Advisory Group is currently engaged in a number of projects designed to assist this development, all of which arise from the numerous complaints we receive and from the subsequent investigations undertaken by the relevant regulator, often the local authority environmental health team. All projects take the JCCP's concerns around patient safety and public health as their primary focus. In many respects, these projects are closely related or interlinked. Including, for example, supervision requirements for ‘Amber’ procedures such as injectable botulinum toxins and dermal fillers, restricting the supply of dermal fillers, remote prescribing and safe and ethical product procurement. The safe, ethical and legitimate procurement of all types of products used in cosmetic procedures forms the basis of this article.

Inappropriate product supply and use is amongst the most common complaints received by the JCCP. Likely reasons for patients and practitioners obtaining products outside of authorised supply routes are twofold; products tend to be cheaper, and prescription-only medicines can be obtained without a prescription. The JCCP has seen an increase in demand of the use of illicit procurement routes in recent years that appears to have driven the illicit supply market. We note the MHRA's recent high-profile prosecutions of suppliers, particularly relating to weight loss injections, unlicensed botulinum toxins and dermal fillers. However, we also find that black market suppliers are often difficult to identify and isolate so that they avoid investigation and prosecution. It is relevant to note therefore, that any efforts found to be effective in reducing this supply route by limiting demand, will also drive down the illegal supply of these products.