The case for banning liquid BBLs

The administration of non-surgical cosmetic procedures such as Botox, dermal fillers, laser therapy and chemical peels has increased significantly in recent years with the Department of Health and Social Care estimating that 900,000 Botox injections are carried out in the UK every year.

The Women and Equalities Committee (WEC) has recently published a report recommending the immediate prohibition of several high‑risk cosmetic procedures, including non‑surgical buttock augmentation commonly referred to as the Brazilian Butt Lift (BBL).

Following the report, the Institute of Licensing (IOL) has highlighted the concerning reality that the rapid rise in BBL procedures presents a significant threat to patient safety. The procedure is often carried out in unregulated settings by individuals lacking appropriate training, creating conditions that are unsafe and difficult to monitor.

MPs have now called for a complete ban on these non‑surgical BBL procedures, describing the current state of the industry as a ‘Wild West’ in which vulnerable individuals are exposed to unacceptable levels of risk.

The Joint Council for Cosmetic Practitioners (JCCP) shares these concerns. Together with the British Beauty Council (BBCo) and the Chartered Institute of Environmental Health (CIEH), it is urging the government to introduce emergency legislation to ensure that invasive cosmetic procedures, including BBLs, are performed only by appropriately trained, GMC‑registered medical professionals.

The regulatory vacuum

BBL procedures are carried out in the UK without any dedicated statutory regulation thereby enabling high‑risk procedures to be performed by individuals with little or no medical training. Reports indicate that these procedures are sometimes undertaken in unsafe and wholly inappropriate environments, including Airbnbs, hotel rooms, garden sheds and even public toilets.

The lack of a robust regulatory framework for high‑risk non‑surgical cosmetic procedures is extensive and leaves significant gaps in oversight, safety, and accountability across the sector. There are no mandatory training requirements, no nationally recognised competency standards or accreditation, and no licensing regime governing either the practitioners or the premises in which these procedures are carried out.

Dermal fillers used in BBL procedures are legally categorised as medical devices. This classification places them outside the prescription‑only medicines regime, meaning their supply and administration are not subject to the safeguards that apply to prescription medication. In practice, this means that individuals with no clinical background can obtain and inject these substances without any requirement for medical oversight, formal qualification, or assessment of competency.

Dangers associated with BBLs

The non‑surgical BBL is a derivative of surgical gluteal augmentation, a procedure that should only be performed by surgeons with appropriate qualifications and competence. Known risks associated with gluteal augmentation include filler or fat embolism, haemorrhage, deep vein thrombosis, pulmonary embolus, sepsis, necrotising fasciitis, thrombotic complications, local anaesthetic toxicity, severe allergic reactions and death.

When these high‑risk non‑surgical BBL procedures are undertaken outside a regulated clinical setting, and particularly by individuals with no surgical training or verifiable competency, they present an immediate and serious danger to patient safety. The lack of appropriate facilities, infection control and emergency response capabilities significantly increases the likelihood of severe harm.

The dangers have been underscored by recent events involving Jordan James Parke, known as the ‘Lip‑King’. In September 2024, Alice Webb, aged 33, died after receiving a non‑surgical liquid BBL reportedly administered by Parke, prompting a manslaughter investigation and renewed calls for regulation. Webb was the first person in the UK reported to have died following a non‑surgical BBL. Parke remained under investigation at the time of his own death on 18 February 2026.

BBLs have the highest mortality rate of any cosmetic procedure, with an estimated death rate of around one in 3,000.

Proposed licensing reforms

The government has proposed a new national licensing scheme for non‑surgical cosmetic procedures, including a ‘traffic light’ risk‑based system.

Under this model:

• Green procedures, for example microneedling, LED therapy, light chemical peels and skincare treatments, would be considered lower‑risk and may be undertaken by trained non‑medics.
• Amber procedures,for example Botox injections, dermal fillers and advanced skin tightening, would require an enhanced level of training, regulation and oversight.
• Red procedures, for example hair restoration surgery, deeper chemical peels and procedures aimed at augmenting any part of the body, will be considered the highest‑risk procedures. These procedures would be restricted to medically qualified practitioners and may even be prohibited entirely.

The JCCP has been heavily involved in shaping the RAG approach to cosmetics licencing and strongly supports the classification of BBLs within the red procedure category, thereby requiring the highest level of regulation within the cosmetics industry.

What can be done in the meantime?

While the government is taking steps to address the current absence of regulation within the cosmetic interventions sector, including proposals for a new licensing regime, there remains no certainty as to when these measures will take effect. Until such time as a statutory framework is implemented, the risks associated with unregulated BBL procedures will continue.

In the interim, those with responsibility for health and safety are not without recourse. Civil injunctions can be obtained against individuals who persist in carrying out cosmetic procedures in unsafe or inappropriate environments. In addition, health and safety legislation provides local authorities, the Health and Safety Executive (HSE) and other regulators powers to issue prohibition or improvement notices where they are satisfied that the manner in which procedures are being undertaken poses a risk of serious personal injury. Local authorities and the HSE can also issue closure notices where they have reason to believe criminal activity is taking place. Practitioners can also be prosecuted for breaches under the Health and Safety at Work etc. Act 1974. These interventions provide mechanisms for regulators to disrupt unsafe practices notwithstanding the absence of a dedicated regulatory regime.

Individuals considering BBLs should not engage in high‑risk treatments without appropriate medical advice. Prospective patients must ensure they fully understand the significant health risks associated with these procedures and should exercise extreme caution when selecting a practitioner or treatment setting.

The Birketts view

The increasing prevalence of liquid BBL procedures highlights a clear and pressing need for regulatory reform. The current regulatory vacuum, in which high‑risk procedures can be undertaken by untrained individuals in non‑clinical settings, creates conditions where very serious harm can occur to vulnerable victims. The proposed traffic light licensing scheme provides a potential system which allows members of the public to make safe and informed choices about any non-surgical cosmetic procedures.  

Birketts’ regulatory and corporate defence team is well placed to support local authorities, regulators and providers who are trying to address unsafe cosmetic practices. We can assist clients with enforcement strategy, policy developments, compliance frameworks, and evidence and disclosure management.