Committee publication · Correspondence · 24 June 2026
Correspondence from Chartered Trading Standards Institute (CTSI), re: Follow-up to the Hair and beauty oral evidence session on 3 June, 15 June
From: Science, Innovation and Technology Committee
Inquiry: The science and regulation of hair and beauty products and treatments
Summary
The Chartered Trading Standards Institute (CTSI) responds to the Science, Innovation and Technology Committee's June 2024 hair and beauty inquiry. CTSI identifies critical regulatory gaps in UK law: self-imported cosmetics by salons, unregulated aesthetic injectables (dermal fillers, fat dissolvers), unsafe products sold via overseas sellers on online marketplaces, and lack of government agility on emerging products. CTSI calls for expanded investment in Trading Standards, a cross-government taskforce, inclusion of Annex XVI products under UK Medical Device Regulations, and improved consumer engagement on product safety.
Key findings
- Self-importing beauty salons importing cosmetics directly from China/USA via e-commerce (Alibaba, etc.) escape UK Cosmetics Regulation because legal definitions of 'placing on the market' assume traditional supply chains with manufacturers, importers, and retailers.
- Most dermal fillers, fat-dissolving injectables, and Glutathione IV drips fall outside UK product safety law (not classified as medicines, medical devices, or cosmetics); no government department has policy responsibility.
- Online marketplaces host overseas sellers using fake 'UK Rep' addresses (often China-based companies acting as mailboxes) to appear UK-established; marketplaces deny legal responsibility and are not held accountable for third-party sellers' non-compliance.
- OPSS lacks agility to address emerging product gaps; refuses to offer opinions on borderline cosmetic/medical products and declines to proactively research harms like nasal Melanotan sprays or professional UV nail gels.
- Trading Standards services face 50% cumulative budget cuts (39% in 2021, 25% more in 2023), with aging workforce; CTSI requests £100 million phased investment, ringfenced funding, and dedicated apprenticeship pathways.
Tone
CriticalTopics
Key actors
Chartered Trading Standards Institute (CTSI), Richard Knight (CTSI Lead Officer for Cosmetics and Beauty), Office of Product Safety and Standards (OPSS), Medicines and Healthcare products Regulatory Agency (MHRA), Health and Safety Executive (HSE), Local Authority Trading Standards Services (LATSS), Amazon (online marketplace), Cosmetic, Toiletry and Perfumery Association (CTPA)
Notable line
“… there is a legal lacuna due to legal basis of EU-derived UK product law that relies on placing on the market as a trigger before products are in-scope and must meet strict …”
Key Quotes
“… to the legal definitions for 2 " placing on the market " and " making available " which rely upon a supply, where there is a self-importing salon who only uses the imported cosmetics for their own use on clients in the salon”
“Amazon is an example of an online marketplace that requires overseas sellers to have a UK address that must appear on products. This requirement has led to a new industry of service providers who act as little more than a mailbox address for (typically) China- based sellers.”
“There is a lack of agility and willingness within the UK Government to accept responsibility for new product types that don't already fall within their department's existing borderlines.”
“OPSS declines to offer opinions on borderline products, and in practice if the answer cannot be found in the latest edition of the EU Manual it frequently falls to the CTSI Lead Officer for Cosmetics and Beauty to offer an opinion.”
“There is no transparency in the system, and the CTSI Lead Officer and CTPA (as the voice of the UK industry) has no real idea what OPSS does with the data …”
“Trading Standards has suffered 39% budget cuts and the 2023 NAO report evidenced a cut of 25% to Regulatory Services budgets.”
“In the GB context, where an Annex XVI product is CE marked as a medical device under EU legislation, if it does not have a medical purpose and is for cosmetic use only then it will not fall within the remit of the UK MDR 2002 as it does not meet the …”
Source · parliament.uk record ↗