GPhC Sounds Alarm on ‘Lemon Bottle’ and Other Unregulated Injectables

The General Pharmaceutical Council has issued a formal warning to pharmacy professionals over the supply and use of unregulated aesthetic products, including the increasingly popular fat-dissolving injection ‘Lemon Bottle’. In a direct communication to pharmacists, technicians and pharmacy owners, Chief Pharmacy Officer Roz Gittins raised concerns that such products could pose a serious risk to patient safety—and that pharmacy professionals are not doing enough due diligence.

“We have received concerns relating to non-medicinal, unregulated, unlicensed products, including ‘Lemon Bottle’ and other products used for non-surgical cosmetic procedures, being supplied by community pharmacies, or being administered by pharmacists via injection in other settings,” Gittins wrote. “We have received concerns suggesting these products have potentially caused serious harm.”

The GPhC's concerns centre on the fact that these injectables are not licensed as medicines or medical devices by the Medicines and Healthcare products Regulatory Agency (MHRA), and therefore do not need to meet the usual safety, quality or efficacy standards. There are additional worries about the lack of transparency in ingredient disclosure and the limited or non-existent clinical safety data.

Gittins reminded pharmacy owners and Superintendent Pharmacists that if they choose to offer these products for sale, “it is their responsibility to make sure that they have sought assurances from the supplier and/or completed their own due diligence that the product(s) they provide are safe for patients and the public. They should also check with their insurers that providing such products is covered by their indemnity arrangements.”

Particular emphasis was placed on injectables, which carry added risk: “In line with our standards for registered pharmacies, they should also consider the associated risks, which includes the risk of administering the product, and particularly if it is by injection.”

Pharmacy professionals supplying or administering such products are also cautioned against making medicinal claims that are not substantiated. “Pharmacists and pharmacy technicians who decide to supply or administer these products should also make sure they do not make any unsubstantiated medicinal claims about them, have appropriate indemnity, and follow the standards for pharmacy professionals at all times.”

The email from Gittins comes amid a broader regulatory push around aesthetic practice in the UK. While ‘Lemon Bottle’ has been heavily marketed as a natural and innovative solution for localised fat reduction, it is not a licensed medical product—and has been linked to adverse reactions such as inflammation, bruising, and infection.

As the popularity of injectable aesthetic treatments grows, this warning underscores the urgent need for tighter oversight and professional accountability. The GPhC’s message is clear: pharmacy settings must not become a back door for unregulated aesthetic interventions.

Natalia Kulak