Why Cheap, Illegal Botox is a Growing Problem — and Why New NMC Rules May Make It Worse
- Sebastian Rose Medical Aesthetics
- 2 days ago
- 7 min read
The number of online shops and social media sellers offering unlicensed prescription-only medicines has surged — and with this has come a worrying rise in people calling themselves "aesthetic practitioners," "advanced aesthetic practitioners," and similar titles (all of which, by the way, mean nothing: these titles / phrases are not protected in such manner as nurse, doctor, surgeon etc).
These individuals, often not regulated medical professionals, are sourcing unlicensed botulinum toxins cheaply and offering anti-wrinkle injections to the public at a fraction of the price charged by legitimate clinics.
This is only possible because they bypass essential safety, legal, and ethical requirements.
A simple Google search, by our author today (6th May, 2025) for products like Botulax (an unlicensed botulinum toxin not authorised for use in the UK) returned dozens of sellers, many of them UK based 'pharmacies', shipping directly to whoever wants to buy them - consumers, 'practitioners', etc. No prescription. No professional verification. No medical oversight.
And it doesn’t stop there. Social media platforms, including TikTok Shop, are now major marketplaces for these products — promoted and sold openly to non-medics and members of the public.
Why Is This So Dangerous?
Prescription-only medicines (POMs) are regulated for good reason. They should only be prescribed after a consultation with a qualified, regulated medical professional who ensures they are safe and suitable for your individual needs.
Obviously, lack of education is a very bad thing, but top this with a lack of ethics, regulation, insurance, and licensing, and you've got a recipe for disaster.
Unlicensed and unregulated products carry serious risks:
Unknown contents and quality — Counterfeit, contaminated, or poorly stored products are common.
No medical oversight — This increases the risk of inappropriate use and dangerous complications.
Legal issues — Supplying or using prescription-only medicines without a prescription is illegal.
There have already been many reported unprecednted and permanent problems with patients receiving unlicensed or foreign botulinum toxins, resulting in sever infection, sepsis, and facial disfigurment
How New NMC Rules Could Make The Problem Worse
From 1st June 2025, nurse prescribers will no longer be able to undertake remote prescribing.
Although this is designed to improve patient safety, in reality it may have the opposite effect . . . Removing regulated medical prescribers from the supply chain for aesthetic treatments risks driving more people towards unregulated and underground sellers who can offer cheaper — but far more dangerous — options.
In short:
As regulated professionals face more restrictions, illegal sellers step in — raising serious safety concerns for the public.
The Prescriber Apps — And Why They’re A Concern
For several years, the industry has seen the rise of apps that connect prescribers directly with "practitioners" — who could be anyone from medically trained professionals to non-medics. These apps have allowed prescribers to issue prescriptions at very low rates — sometimes as little as £10 or £15 per prescription — without ever seeing the patient face to face.
This model means that currently - and until 1st June 2025, Ben in Bradford (or Sarah in Sunderland - these are not real people!) can sit at home, issuing hundreds of prescriptions a day for patients all over the UK, without any real clinical oversight. And whilst the new NMC regulations are intended to put a stop to this sort of nonsense by requiring face-to-face consultations, many of these apps, as far as we are aware, are still operating, and will probably continue to do so. How do we know this? Well, the GMC put a 'ban' on remote prescribing for GMC doctors quite some time ago - and yet, many doctors have continued to ignore this and make a quick 'easy' money . . . and therefore, will likely, conitnue to do so, unless they are reported.
In practice, whilst both Ben and Sarah can (supposedly) no longer issue 300 remote prescriptions a day without breaking the law, this does not stop poorly-minded individuals from simply bypassing the professional system altogether and purchasing illegal and unlicensed botulinum toxin products online. One might think this would often be from overseas, but we guarantee you that at the time of writing this blog, there are plenty of UK based warehosues offeing thse products without buying from abroad. In fact, we could order foreign botox today, and inject it into your face tomorrow.
And you wouldn't know, unless you ask the question.
The Growing Responsibility and Pressure on Prescribers
Of course, regulated prescribers can still work with non-prescribing colleagues, both medics and non-medics, as long as face-to-face consultations take place. However, this comes with significant responsibility and pressures.
For example:
Jane (a doctor) consults face-to-face with Sarah (the patient).
Bethany (an aesthetic practitioner — who could be a nurse, paramedic, or non-medic) injects the product.
If something goes wrong, it is Jane who is fully responsible.In situations such as vascular occlusion, Jane would need to be readily available to prescribe and oversee emergency treatment.
This level of responsibility — combined with practical demands like travelling to clinics and balancing other professional commitments — means that for many prescribers, continuing in this role is becoming increasingly difficult.
Why Legitimate Clinics May Need to Raise Prices
Understandably, there is increasing discussion across the industry that the cost of safe, legal prescription only treatments such as Botox, Alluzience, Vitamin B12 and more will need to rise.
Prescribers will now have to :
Spend more time in face-to-face consultations.
Travel more often.
Carry heavy responsibility for patient safety and outcomes - for patients who may not, on paper, be 'their' patients (until now).
At Sebastian Rose Medical Aesthetics, we want to be fully transparent.
At this time, we have no plans to substantially increase our prices.However, as we approach June 1st 2025, we may need to make small adjustments to reflect the additional time and responsibility required by the new legislation.
Any price changes will not take effect before June 1st 2025, and we are actively working to find the best way to manage this for both our clinic and our patients.There is also the possibility that some changes may come into force before June 1st to help us prepare for the new regulations.
Our priority remains balancing patient safety, clinical excellence, and affordability.
The Widening Gap Between Safe and Unsafe Treatments
Of course, there may - will, be non-prescribing medics and non-medics out there who, in actuality, are going to pay (potentially more) for their prescribers to come to their clinics and see their patients face to face, and pass that cost on to their patients. There may even be some prescribers out there who do not charge more for their time or travel, and therefore, the non-prescribing practitioners delivering the tretaments may not, therefore, raise their prices either. But I think we all know where the majority of this is headed...
The unfortunate reality is that as licensed clinics may need to raise prices slightly, unlicensed and unregulated sellers may continue offering "cheap Botox" using illegal and potentially dangerous products - thereby passing the prescribers, laws, legislation, and increased cost. Or, you know...they may raise their prices anyway (so their average customer thinks they are acting legitimately), whilst in actuality, they are offering cheap, unregulated Chinese botox and just pocketing the extra money...
The very big point here is: unregulated people can pretty much do what they like, without any - or little, real-life consequence.
Regardless, this growing price gap risks pushing more people towards underground treatments — often without understanding the very serious risks involved.
What You Must Ask Before Any Anti-Wrinkle Injection
Before having any anti-wrinkle injection, always ask:
"What is your job title and qualification?"
If the person injecting is NOT:
A GMC-registered doctor, or
An independent medical prescriber (such as a nurse, pharmacist or dentist)
... and you have NOT seen one of these prescribers face-to-face beforehand, then what is in the syringe could be:
a) A licensed product illegally obtained and prescribed.
b) An unlicensed, foreign product sourced illegally online.
c) A completely unknown and unregulated substance
This Is Not About Medic vs Non-Medic
We want to be clear — this is not about medics versus non-medics.There are highly skilled and ethical practitioners (and unfortunately, just the opposite!) in both groups.
The issue is about the product and supply chain:
Was it sourced legally?
Was it prescribed responsibly?
Is the treatment properly overseen by a qualified professional?
Without this, even the most skilled practitioner cannot ensure patient safety.
Stay Safe — Stay Informed
At Sebastian Rose Medical Aesthetics, patient safety will always come first. We will continue to work in the safest, most ethical way possible — in line with the new regulations — and will keep our patients updated every step of the way.
If you see sellers offering unlicensed, unregulated botulinum toxin / and or regulated, allegedlly licensed botulinum toxin without any checks to ensure they are selling to prescribers (doctors, and other non-medical prescribers) - be it online or through social media, you can report them to:
MHRA Yellow Card Scheme
Trading Standards (via Citizens Advice)
Advertising Standards Agency
Report them to the social media platform on which it is hosted, Facebook, Instagram, TikTok, etc
In summary:While new regulations aim to protect patients, they may unintentionally drive aesthetic treatments underground — increasing the appeal of unsafe and illegal options.
This blog has been written to help you understand the risks, the reasons behind the changes, and why choosing a regulated, qualified professional using licensed products is more important than ever. We hope you found it useful.
If you have any questions or concerns, we are always here to help and guide you - feel free to get in touch with us anytime. We welcome enquiries.
