Pillar Three:
Regulation Isn’t Erasure
Regulation isn't erasure: Three (Now Four) Paths. One Choice.
Education is only the beginning. Once we agree on what should be taught, the next question is: who ensures it’s delivered properly, followed consistently, and backed by professional accountability?
That’s where regulation comes in.
You’ve landed here at Pillar 3: the structural bit. Where we ask not just what should change—but how do we hold it in place?
Yes, these pillars overlap—education, messaging, and recognition are all part of the same framework. But regulation is what makes the rest of it real. Without it, there’s no one responsible for upholding standards, protecting the public, or supporting the professionals delivering skin-facing care.
Before we even go there, though, we ask a bigger question: Is this even feasible?
The fork in the road
There are three main routes the UK could take:
Path 1: Restrict advanced skin treatments to medical professionals.
This model already exists in countries like Germany, Belgium, and parts of the United States. Microneedling, chemical peels, and injectables are classified as medical procedures and restricted to doctors, nurses, and medically licensed clinics. Skin care becomes a health issue only when it crosses into medicine.
This route is clean, clear, and comes with an existing accountability structure. But it excludes non-medics entirely—even those with in-depth training—and reinforces a false divide between health and beauty. It also removes the possibility of building a preventative, early-intervention skin health workforce from within the personal care sector.
It protects, yes. But it erases too much.
Path 2: Create a full professional framework for medics and non-medics.
This is what The Skin Well™ is calling for:
A statutory regulator
Health-guided education
Protected titles
A national register of professionals (medics and non-medics)
It’s the harder path, but it’s the one that recognises what all skin-facing professionals already do—and what they could do, with the right backing. It sees skin as part of health, and it sees trained professionals—whether their background is medical, aesthetic, or personal care—as part of the solution.
This route means skin care wouldn’t default to medics, but would be brought into alignment with health—through education, standards, accountability, and public messaging.
It doesn’t erase anyone. It builds something better.
Path 3: License the premises and the practitioner.
This is the model currently being proposed under the Health and Care Act 2022. It sounds protective—but it may not go far enough.
Licensing both the premises and the person gives the appearance of regulation, but without national oversight of training, professional conduct, or post-qualification support, it’s just a shell. It’s the same model used for electrolysis and tattooing: once you’re licensed, you’re on your own.
There is no register, no CPD, and no one ensuring standards after the license is issued. If the UK stops here, very little will change—except the paperwork.
But what if there’s a fourth model?
Phase 2+: The French Approach (2024)
In April 2024, France introduced a new framework for laser and IPL hair removal. It extended permission for these procedures to trained non-medical professionals—but under strict national controls:
A nationally mandated training course
Refresher training every 5 years
Medical supervision (e.g., by a dermatologist or plastic surgeon)
Mandatory briefings on contraindications and consent
Adverse event reporting
Licensing of both practitioner and premises
We’re calling it Phase 2+ because it doesn’t replace statutory regulation. But it goes further than the UK’s current proposal—and proves that safety doesn’t require erasure.
That said, it’s still procedural. It regulates what’s done, not the full professional structure behind it.
There’s no statutory register. No protected titles. And no framework for those working across the full spectrum of skin work—from early-stage skin support and prevention, to education, corrective care, and aesthetics.
It’s a promising step—but not a full solution. Because skin isn’t just a treatment. It’s a profession.
What do we really want?
We don’t want aesthetics to disappear.
We don’t want regulation used to shut people out.
We don’t want more fear, more confusion, or more red tape for the sake of it.
What we want is a framework that finally sees skin care for what it is: a health issue that deserves structure, safety, and standards.
Some believe the UK may be considering a model similar to France’s recent move—a middle path where non-medics are included under structured oversight. That’s only speculation for now. What we do know is that the current plan involves a licensing scheme, which suggests that non-medics will still be involved. But the key question remains: will that scheme go far enough? Will it regulate only the treatment—or also the education, support, and accountability behind it?
That’s the heart of this conversation. Because skin is health—and regulating it means more than just approving what’s done. It means understanding how, by whom, and for whose benefit.
The Skin Well™ believe regulation doesn’t shut doors. It opens them—responsibly.
🡒 Continue reading: [Next article in Pillar Three coming soon…]
June 2025
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The Skin Well™
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Disclaimer
A Clear Case for National Skin Health is part of an independent advocacy series by The Skin Well™. These pieces are written from lived professional experience and personal reflection. They are intended to raise questions, highlight gaps, and explore opportunities for public health improvement.
They do not replace professional medical advice, and they do not represent the views of the NHS or any governmental body.
It should not be used as a substitute for professional medical advice, diagnosis, or treatment. If you have concerns about your skin or health, please speak with your GP or a qualified healthcare provider.
I welcome constructive feedback. If you notice any information that may be inaccurate or outdated, please let me know so I can review and improve.
© 2025 Jacqui de Jager | The Skin Well™ & The Happy Skin Clinic®
All rights reserved. This leaflet is for personal use and education only. It may not be reproduced, distributed, or adapted without written permission.