Dear Councils of England,

For more than 30 years, local authorities have been expected to license certain treatments — but without national regulation, consistent guidance, or a clear definition of risk. This letter is an invitation to pause, reflect, and ask whether the current system is still serving your communities.

How We Got Here

The Local Government (Miscellaneous Provisions) Act 1982 gave councils the option to adopt licensing powers for certain treatments — like electrolysis, acupuncture, tattooing, and cosmetic piercing — through local by-laws.

Later, in London, the London Local Authorities Act 1991 made licensing mandatory for ‘special treatments’ including massage, manicure, light, electric, vapour, sauna, or treatments of a ‘like kind’. London boroughs were required to enforce these rules, but they were also left to interpret and apply them — including how to define risk and how to structure fees.

Outside of London, councils had no national mandate to license many of these treatments. Some adopted the 1982 Act and wrote local by-laws. Others did not. Some added powers via private local Acts, or interpreted ‘special treatment’ based on legacy rules. This patchwork approach has led to widespread inconsistency, confusion, and concern.

What This Means in Practice

Today, there are 317 local authorities in England, and:

• Some require premises licenses, some require personal practitioner licenses, and some require both — or neither.

• Fees range significantly, often costing hundreds of pounds per year, with no standardisation.

• Many councils have no publicly available by-laws.

• Laser and IPL may be licensed in one borough, but unregulated in the next.

• LED, which is classified as low risk by the MHRA, is sometimes treated as if it were a laser.

• Practitioners are often unclear whether they need a license, what it covers, or who enforces it.

• Complaints about practitioners are rising — but councils don’t always have the tools or authority to respond.

Barnsley and Birmingham: A Snapshot

Barnsley Council, for example, licenses acupuncture, electrolysis and tattooing under the 1982 Act — but not lasers, LED, or massage. Meanwhile, the London Local Authorities Act 1991 exempts doctors, dentists, and those working under their direction from licensing requirements. This means that even non-healthcare professionals may be exempt if employed within a healthcare setting — despite not always being formally trained in the procedures they carry out or oversee.

However, the Act also gives councils discretion to require licences anyway — adding yet another layer of variation.

Birmingham City Council sets separate fees for each “level” of special treatment, but the system is vague. Its 2024 licensing schedule lists charges for electrolysis, massage, and multi-level treatments, but offers no central by-law document for the public to read. The council’s own guidance states:

“There are no powers to refuse registration.”

These are just two of the 317 authorities making independent decisions — without national guidance or standardised risk frameworks.

And Now — A New Licensing Scheme

The government is introducing a new national licensing scheme for non-surgical cosmetic treatments. But early drafts suggest it will focus only on a limited set of high-risk aesthetic procedures — while leaving everything else (massage, facials, LED, barrier repair, and more) outside the framework.

That means:

• Some treatments will fall under new national licensing

• Others will remain under local council licensing

• Others still will remain unlicensed entirely

• And every council will continue to interpret risk, cost, and enforcement in its own way.

This isn’t simplification. It’s a doubling-down on complexity.

A Better Way Forward

The Skin Well® is asking for your support. Not for more local bureaucracy — but for something better.

Believing that:

• Skin should be treated as a health organ, not just a service

• Practitioners who work on skin — regardless of modality — should be regulated, qualified, and nationally recognised

• The public deserves transparency, accountability, and protection

• Local councils deserve clear guidance, consistent standards, and national backing

Regulation does not mean more red tape. Done properly, it would:

• Remove ambiguity

• Protect local residents

• Reduce enforcement pressure on councils

• Restore public confidence

The Skin Well® does not believe local authorities created the current mess. But is inviting you to help change it.

This is a pivotal moment. And councils have a voice.

With respect and appreciation,

The Skin Well® Project