11th Report – Cosmetic procedures

The PIP implant scandal exposed failures that continue to affect women more than a decade later. Official assurances that PIP implants pose no health risks appear to be based on limited long-term research and underplay the mental health impacts on women of having a substandard product inside them. Many women report enduring physical and psychological harm, compounded by inadequate follow-up and dismissal of symptoms. Shortcomings on data collection and recording mean that the NHS does not know who received PIP implants and many women may not be aware they have them. The need for further research and improved data collection on implantation must be addressed. (Conclusion, Paragraph 18)

While there is a judgement to be made over whether the NHS should offer replacement implants to women affected by the PIP implants scandal, women with PIP implants who wish to have them removed should be able to have that request met by the NHS as stated by its own guidance. Reports that such requests are being turned down are troubling, not least given the evidence of the benefits of explantation for some women. The NHS should remove PIP implants from women who wish to have them explanted. (Recommendation, Paragraph 19)

Without mandatory participation in the Breast Implant Registry and the regular publication of outcome data, surgeons cannot provide patients with comprehensive risk information. This undermines the principle of informed consent. Many individuals feel inadequately informed before surgery and the absence of a cooling-off period further increases the risk of rushed decisions. As the PIP scandal demonstrates, a lack of data collection makes it more difficult to identify products with increased risks and those who have received them. (Conclusion, Paragraph 24)

The Government should introduce mandatory recording of breast implant and explant procedures and instances of adverse outcomes in the Breast and Cosmetic Implant Registry by the end of 2026. We welcome the Government’s acknowledgement that the registry requires improvement. The Government should work with practitioners to ensure 44 the registry meets the needs of surgeons and patients, including on ease of use. Data on adverse outcomes by implant type should be published annually to support informed consent and improve patient safety. (Recommendation, Paragraph 25)

We note that the registry is currently overseen by the soon-to-be abolished NHS England. The Government should take steps to ensure that the improvements we call for are not delayed by internal reorganisation. (Recommendation, Paragraph 26)

A mandatory cooling-off period of at least two weeks should be introduced between the initial consultation and surgery for breast implants, ensuring patients have sufficient time to consider risks and alternatives before making a commitment. (Recommendation, Paragraph 27)

The PIP implant scandal involved substandard implants being given to women for many years without detection. The new post-surveillance regime for breast implants must include regular testing of approved implants to ensure continued compliance with safety standards. (Recommendation, Paragraph 35)

The Government should increase the information available on the approval of medical devices to allow interested parties to see not only what devices are approved but the evidence base underpinning the decisions to approve them. (Recommendation, Paragraph 36)

There is growing concern that a number of women are experiencing serious health impacts after receiving breast implants, with many reporting symptom improvements following explantation. While evidence of a definitive link between these symptoms and breast implants has not been established, this does not mean there is not a connection. (Conclusion, Paragraph 44)

Evidence of concentrations of siloxanes in women’s bodies outside of their implants is particularly concerning. The mental health impacts of knowing that chemicals, which are being banned in other uses due to their toxicity, are circulating in your body should not be underestimated or dismissed. This is particularly true for women who received PIP implants, which have higher rupture rates, lower grade silicone and higher levels of D4 siloxane. (Conclusion, Paragraph 45)

The Government should commission research to better understand the health impacts of breast implants, including their potential impacts on women with pre-existing auto-immune conditions. The research needs to be a mix of clinical research, including on the health impacts of siloxanes, and longitudinal, following a cohort of women over a period of time. Such studies are necessary to improve patient safety, diagnosis and 45 treatment and for the purposes of informed consent. At present, we do not believe that enough information is available about breast implants for women to genuinely be able to give informed consent to receiving them. (Recommendation, Paragraph 46)

The Department of Health and Social Care should make primary care workers aware of the potential for a link between autoimmune conditions and breast implants to ensure that women presenting with symptoms following implantation are not dismissed. (Recommendation, Paragraph 47)

Currently, any doctor on the medical register can legally perform highly invasive cosmetic surgery in the private sector, regardless of specialist training or competence. This is a risk to patient safety. Despite the introduction of the Intercollegiate Cosmetic Surgery Certification Scheme in 2017, participation remains voluntary. (Conclusion, Paragraph 51)

The Government should require all practitioners performing invasive surgical cosmetic procedures to have specialist training and hold appropriate board certification in the procedures they undertake. (Recommendation, Paragraph 52) Non-surgical cosmetic procedures

We welcome the proposals for a licensing scheme put forward in the Government’s consultation, including the proposed categories and the need for a practitioner to acquire appropriate indemnity cover and premises which meet the necessary standards of hygiene, infection control and cleanliness to obtain a licence. (Conclusion, Paragraph 68)

However, the Government is not moving quickly enough in introducing such a system. At present, individuals without any formal training can carry out potentially harmful interventions, placing the public at risk. Successive Governments have failed to act swiftly enough to legislate in this area allowing further harms to occur. The Government’s announcement of yet another consultation will cause more delays. This lack of timely action is fostering complacency in self-regulation within the industry and is compromising patient safety. (Conclusion, Paragraph 69)

The Government should accelerate regulatory action. Procedures that are deemed high risk such as liquid BBLs and liquid breast augmentations, which have already been shown to pose a serious threat to patient safety, should be restricted to appropriately qualified medical professionals immediately. Given the lack of appetite among medical professionals to carry out these procedures, this will act as a de facto ban in all but the 46 most essential cases. A licensing system for ‘green’ and ‘amber’ non- surgical cosmetic procedures should be introduced within this Parliament. (Recommendation, Paragraph 70)

The absence of a legislative framework for training and qualifications in the non-surgical cosmetic sector has resulted in significant variability in standards, with justified concerns about short courses, online training, and the ease of entry into practice. (Conclusion, Paragraph 77)

The Government should bring forward consistent, enforceable standards for the non-surgical cosmetic sector that prioritise patient safety and competency, while ensuring training routes remain accessible and affordable for a predominantly female-led workforce. Training routes should include Ofqual-approved qualifications and apprenticeship models, including funded apprenticeship places in SMEs in the beauty industry, to ensure affordability and accessibility, particularly for the existing workforce, while eliminating short, inadequate courses. (Recommendation, Paragraph 78)

While Scotland has taken steps to introduce a licensing scheme for non-surgical cosmetic procedures, Wales and Northern Ireland have yet to announce similar plans. This lack of regulatory alignment across the UK creates significant risks, including inconsistent safety standards and the potential for ‘cosmetic tourism’ within the UK, where individuals seek treatments in jurisdictions with weaker protections. (Conclusion, Paragraph 81)

The Government should work with the devolved administrations to ensure regulatory alignment across all UK nations on legislation governing non- surgical cosmetic procedures. (Recommendation, Paragraph 82) Cosmetic tourism

The increasing number of cases requiring medical treatment after cosmetic surgery abroad raises serious concerns for patient safety and places additional financial strain on the NHS. However, the true extent will remain unknown until comprehensive data is collected. (Conclusion, Paragraph 94)

The Government should review the need for the NHS to systematically record data on complications arising from cosmetic procedures performed abroad. Publishing such data in an annual release would enable a comprehensive assessment of the financial impact on the NHS and provide robust evidence to better inform and educate the public about the risks associated with cosmetic tourism. Where possible, the data set could include details of the clinic or practitioner that performed the original procedure to help further protect UK nationals. (Recommendation, Paragraph 95) 47

We welcome Government action on educating the public on the risks of travelling abroad for cosmetic procedures and providing guidance on how to do so as safely as possible and its use of social media channels to do so. With the number of people engaging in cosmetic tourism growing rapidly, this effort must be sustained, and educational materials should remain simple and widely accessible and supported by the data release we recommend. (Conclusion, Paragraph 96)

The Government should assess whether outlets in the UK that are recruiting patients for medical treatment overseas should be brought into a regulatory regime and be subject to investigation and, where necessary, sanction. (Recommendation, Paragraph 97) Body image

There appears to be a gap in safeguarding mental health in the cosmetic procedures sector. The absence of mandatory psychological screening prior to procedures, combined with evidence of inadequate consultations, increases the risk of harm, particularly for vulnerable individuals such as those with Body Dysmorphic Disorder, who are more likely to want cosmetic surgery and less likely to be satisfied with the outcome. (Conclusion, Paragraph 104)

Training curricula required to obtain a licence to perform non- surgical cosmetic procedures should include mandatory modules on informed consent and psychological screening, with a specific focus on identifying Body Dysmorphic Disorder and other vulnerabilities. (Recommendation, Paragraph 105)

Social media platforms and face-editing technologies are contributing to worsening body image and increasing demand for cosmetic procedures, particularly among young women and girls. The normalisation of high-risk procedures by online influencers and the shaping of beauty standards by algorithms which bombard users which posts on body image are particular concerns. There is no easy solution to these problems, but it is clear that social media platforms must take more responsibility for the content they promote. (Conclusion, Paragraph 117)

One way of addressing the risks posed by social media around cosmetic surgery and body image is through education. Proactive interventions in an educational setting can equip young people with the skills to critically engage with social media content and challenge unrealistic beauty standards. (Conclusion, Paragraph 118) 48

In response to the alarming increase in desire for cosmetic surgery among teenagers, the Department of Health and Social Care should work with the Department for Education to integrate evidence-based body image and social media literacy programmes into school curricula. This should include content on risks of cosmetic procedures. (Recommendation, Paragraph 119) 49