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Section 180: cosmetic licensing in England

GuidesLegal explainerDHSC
Summary: Section 180 of the Health and Care Act 2022 gives the Secretary of State power to make regulations about specified non-surgical cosmetic procedures in England. It does not itself create a live personal or premises licensing requirement.

What is Section 180?

Section 180 of the Health and Care Act 2022 is an enabling power. It gives the Secretary of State for Health and Social Care the authority to make regulations that would:

The Act received Royal Assent in April 2022, and Section 180 has been in force since 1 July 2022. It is an enabling power: the detailed licensing requirements would need to be set by regulations for specified procedures in England.

What counts as a cosmetic procedure?

The Act defines a cosmetic procedure as:

"A procedure, other than a surgical or dental procedure, that is or may be carried out for cosmetic purposes."

The definition explicitly includes five categories of procedure:

Use horizontal scrolling to view the full table.

Category What it covers Examples
(a) Injection of a substance Any substance injected for cosmetic purposes Botox, dermal fillers, fat-dissolving injections, PRP, polynucleotides, biostimulators, mesotherapy
(b) Application of a substance penetrating the epidermis Substances applied to the skin that penetrate into or through the outer layer Chemical peels, skin needling with active ingredients, transdermal delivery
(c) Insertion of needles into the skin Needle-based procedures for cosmetic purposes Microneedling, mesotherapy, semi-permanent makeup
(d) Placing of threads under the skin Thread-based procedures PDO, PLLA, and PCL thread lifts, barbed threads
(e) Application of light, electricity, cold or heat Energy-based devices for cosmetic purposes Laser hair removal, IPL, radiofrequency skin tightening, cryolipolysis, HIFU

This definition is deliberately broad. It supplies the categories from which a future England scheme could specify procedures; it does not itself make every listed procedure subject to a licence. Surgical and dental procedures are explicitly excluded.

How a future licensing scheme could work

The Act permits regulations to create a framework for two types of licence:

Personal licence

A licence granted to an individual authorising them to carry out specified cosmetic procedures. The regulations would specify which procedures require a licence and the conditions attached.

Premises licence

A licence for the premises from which cosmetic procedures are carried out. Before granting a premises licence, the regulations may require the premises to be inspected.

If regulations create the scheme, licences would be issued by local authorities. The Act specifies which bodies count as local authorities for this purpose, including county councils, district councils, London borough councils, and combined authorities.

What Schedule 19 adds

Schedule 19 of the Act sets out what the regulations may include. This is significant because it shows the enforcement framework Parliament already approved:

Current status (reviewed August 2026)

Section 180 is a power to make regulations; it does not itself license a practitioner or premises. The DHSC consultation response, updated on 7 August 2025, sets out policy proposals rather than a live licensing scheme.

The response says the government will prioritise work on restrictions for procedures considered highest risk, while continuing work on local-authority licensing for lower-risk procedures. It does not itself set a commencement date, prescribe a complete operative list of procedures, or create a personal or premises licence.

Any operative scheme would be made through secondary legislation. Check the official DHSC material and the relevant local authority before treating a proposal, a risk category or a consultation response as a current legal requirement.

Separate Scottish position

Section 180 is an England-only enabling power. Scotland has a separate legislative process; see the related Scotland update for that distinct framework rather than treating this article as a UK-wide licensing rule.

Who could be affected by future regulations

What to watch next

We will update this article when official regulations, a consultation or a commencement date are published.

Disclaimer: This article is for informational purposes only and does not constitute legal advice. Clinics and practitioners should seek independent legal advice for their specific circumstances.