When you take out any insurance policy, it is vital to avoid accidentally invalidating your cover or, worse, putting a patient at risk as a result of a genuine error. At Hamilton Fraser, we aim to raise awareness of some of the oversights that aesthetic practitioners sometimes make, which may inadvertently invalidate their insurance and cause harm to their customers.
One of the most pressing issues in today’s aesthetics landscape is the rise of grey market and counterfeit products. With unlicensed fillers, untraceable toxins, and fake weight-loss injection pens increasingly available through online marketplaces and overseas suppliers, both regulators and insurers are raising the alarm.
In June 2025, the Chartered Trading Standards Institute (CTSI) issued an urgent warning that “vulnerable consumers are increasingly exposed to unsafe practices and products that pose a risk to their health and safety.”
With major gaps in regulation around product responsibility, CTSI has called for tighter controls and the removal of unsafe products sold online.
In this article, we explore what grey market and counterfeit products are, outline the latest warnings from UK authorities, and explore how you can make sure you are covered.
Grey market products are legitimate medical devices or medicines manufactured by an approved company but sold outside authorised distribution channels.
The main issue is that their origin and distribution journey cannot be sufficiently traced. Without assurances on storage, transport, or licensing, products may be compromised, expired, or even counterfeit — posing a serious risk to patients.
Tempting bulk discounts on fillers, toxins, or weight-loss injections from overseas wholesalers or online platforms such as Amazon or eBay are a major red flag. Under no circumstances should these products be used on patients.
Legitimate products will always be traceable — with CE or UKCA markings for devices, MHRA licences for medicines, and batch codes for traceability. These should be recorded in a patient’s notes to create a clear audit trail. As the saying goes, if a deal seems too good to be true, it probably is.
Unlike grey market products, counterfeit products are imitations of licensed brands, often with falsified packaging, safety data, or batch codes. According to reports, more than 40% of practitioners have encountered counterfeit products, with many reporting patient complications.
Recent cases include:
These incidents demonstrate how counterfeit and grey market products bypass every safeguard, leaving practitioners — and patients — exposed.
For more, read The Invisible Risk Behind Unregulated Botulinum Toxin (Botox-like) Treatments authored by award-winning nurse Julie Scott and supported by the JCCP, a patient-facing education tool that also serves as a valuable resource for practitioners, offering a safety checklist and reporting advice that clinics can integrate into their own protocols.
No. In the event of a claim, insurers will require proof of manufacturer and batch codes, and may request purchase invoices. If a product is found to be sourced from an unauthorised supplier, the claim can be repudiated, and the policy may even be cancelled.
“It is important to make sure that all products have been sourced from reputable and listed suppliers. At Hamilton Fraser, we would be unable to cover any practitioner who performed cosmetic procedures using unauthorised products. We carry out careful checks when we add new fillers to policies and our underwriting criteria.”
— Emma Bracchi, Senior Claims Technician at Hamilton Fraser
Check your policy conditions carefully. All products must carry the CE/UKCA markings and/or have an MHRA licence.
In August 2025, the Medicines and Healthcare products Regulatory Agency announced two important online services to help combat the illegal sale of medicines:
These tools are designed to empower people considering purchasing medicines online by:
You can access the new services here:
Red Flags that could put your patients and cover at risk
It is incredibly important to make sure that quality and standards are maintained at all times, not only by using reputable manufacturers but also by making sure that you are purchasing them from an authorised distributor.
Always check that you are sourcing from a legally operating, listed and reputable supplier and keep a full audit trail of your order history.
Here are some tips to help you stay compliant:
1. Purchase only from authorised UK distributors and pharmacies
Only purchase products through regulated UK suppliers or pharmacies. Ask for batch numbers, MHRA licences, and cold chain documentation.
Many prescribers and clinics source products through established UK pharmacies that are regulated and routinely inspected. These suppliers can provide full documentation including batch numbers and cold-chain records. Go to the General Pharmaceutical Council website to check their register.
2. Audit stock regularly
Make sure all products are traceable, approved for UK use, and sourced from a regulated supplier. Record batch numbers, expiry dates, storage conditions, and supplier invoices.
3. Check the labelling
Look for UKCA or CE marks for devices and MHRA licenses for medicines. Check for intact seals, and correct English-language instructions. Be wary of international products with no UK registration.
4. Educate your team
Make sure all staff, including front-of-house, understand the difference between licensed and unlicensed products and the importance of sourcing from the right channels.
5. Report concerns
Use the MHRA’s Yellow Card Scheme to report counterfeit or adverse reactions. This helps authorities track dangerous trends and issue warnings more effectively. It’s also worth noting that not all products used in aesthetics fall under MHRA scope. For example, cosmetic creams, serums, and devices may instead fall under the remit of the Office for Product Safety and Standards (OPSS). Practitioners should familiarise themselves with OPSS guidance and report concerns about non-medical products directly via the OPSS website.
6. Check your insurance cover
Your insurance must reflect your products and procedures. Always check whether your insurer covers adverse events linked to product origin or batch issues. Hamilton Fraser, for example, will only provide cover for approved and appropriately sourced products.
While it may seem tempting to take advantage of the convenience and discounts offered by grey market or counterfeit products, it is never worth the risk. Using unauthorised products could invalidate your insurance, damage your reputation, and most importantly, endanger your patients’ health.
By sourcing responsibly, keeping full records, and staying informed on regulatory updates, you protect not only your patients but also the future of your practice.
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