Dermalogica Expresses Concerns Over Scope of Treatments in Proposal for Licensing of Cosmetic Procedures

In a joint open letter, Mark Hermann, General Manager, and Angela Taylor, Education Director of Dermalogica, have outlined the brand's standpoint on the forthcoming licensing regulations for non-surgical cosmetic procedures by the Department of Health and Social Care. The focus is on the scope of procedures that skin therapists—distinct from medical professionals—will be authorized to perform under the new licenses.

Dermalogica, a professional-grade skincare brand, has championed for the recognition and upskilling of skin care professionals over the past 40 years. The brand’s concerns arise from the classification of some procedures under the 'amber' category, which in their view, could potentially question the competency of qualified skin therapists and aesthetics practitioners.

Surprisingly included in the licensing scope are procedures like electrical epilation and radio frequency, currently under the purview of Level 3 practitioners. Dermalogica finds the implications of oversight on experienced practitioners with proven competency unnecessarily restrictive. They argue that the lack of defined parameters makes it challenging to accurately assess risk profiles, potentially leading to confusing, overly restrictive licensing.

“We are deeply concerned that the competency of qualified skin therapists and aesthetics practitioners  may be called into question with some procedures being classified within the amber category. Some  of the listed procedures and modalities such as electrical epilation and radio frequency currently fall  within scope of Level 3 practitioners and are a surprising addition as these procedures were not  expected to be within the scope of the license. The implication that these practitioners, many with  years of experience and excellent procedure results, cannot operate without oversight seems  unnecessarily prohibitive when competency can be proven. 

This leads to the question of risk profile and the evidence used to determine the classification of the  amber procedures. It is understandable that prescription only medications and higher risk procedures  may require oversight, but there appears to be very broad classification of some procedures and  those that may be used successfully in combination for well-rounded client benefits. Without clarifying  levels of skin effect, depth of action, range or frequency of devices it is not clear on what basis the  classification has been assigned. “ writes Mark Hermann and Angela Taylor.

The full letter can be read here.

The brand finds a persistent misconception equating the competency of non-medics to a Level 2 ‘beautician’, while many practitioners operate at levels 3 through 7, with extensive specialist knowledge and experience in skin treatment. Meanwhile, there are no restrictions on the public purchasing microneedling and other devices for home use, a situation Dermalogica finds concerning due to the risks associated with improper sterilization and post-procedure care. They emphasize the need for these procedures to be conducted by professionals adhering to National Occupational Standards.

Dermalogica is open to sharing data and insights to inform decision-making on procedure classifications, aiming for a balanced approach between risk level and the need for oversight based on a practitioner's training and qualifications.

The brand warns of a potentially catastrophic financial impact on a sector still recovering from Covid-19 fallout, should the licensing become overly restrictive. The prohibition or restriction on professionals from providing advanced and combined therapy services—often at a higher price point—may severely affect the survival of their independent businesses. The beauty industry, in conjunction with the hair sector, contributes a significant £5.1 billion to the UK economy.

Have your say in the consultation for the proposal to License non-surgical cosmetic procedures in England here. The consultation period will run until 11:59pm on 28 October 2023.