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Evidence and complaints

How to check a claim about a product or a device

Evidence11 min read
An embossed seal impression with no wording. A mark means what the scheme behind it says it means, and no more.

An embossed seal impression with no wording. A mark means what the scheme behind it says it means, and no more.

The short answer

Ask for the product or device by full name, then test the claim by type. Regulatory status is a matter for the MHRA and the conformity marking regime, and a marking relates to the product being placed on the market rather than to any practitioner. Clinical claims should be traceable to published evidence you can look at. Approval by a regulator of a specific treatment result is a claim that should always be checked, because it is rarely what it sounds like.

Products and machines carry a lot of vocabulary: approved, certified, medical grade, clinically proven, patented. Each of these words has either a specific meaning, a vague one, or none. Sorting them takes a few minutes and it is the same method each time.

Get the name first

Nothing can be checked without a name. Ask, in writing, for the full product or device name and the manufacturer. A clinic proposing to inject something into your face, or to use a machine on your skin, can name it.

If the answer is a treatment brand rather than a product, ask again for the product and manufacturer. Treatment names are marketing labels and are frequently applied to different underlying products in different places.

Register check 01What the regulator actually says about a product category
Open
The Medicines and Healthcare products Regulatory Agency on GOV.UK
gov.uk, MHRA guidance and the Yellow Card scheme at yellowcard.mhra.gov.uk
Type in
The full product name and manufacturer as given to you in writing. Look for the product category, whether it is regulated as a medicine or a device, and any published safety information.
A good result looks like
Clear information about how the product category is regulated, and a route to report a problem, so that you can describe the product accurately rather than by its treatment name.
An ambiguous result looks like
A treatment brand name that does not correspond to any product you can identify. A clinic unwilling to name the manufacturer. Claims of approval that name no approving body.
What it does not prove
That the product is suitable for you, that the practitioner is trained to use it, or that a cosmetic result has been endorsed by any regulator.
Note
Whatever you find, ask that the product name and batch number are written in your notes on the day.

Regulatory status claims

The Medicines and Healthcare products Regulatory Agency is the UK regulator for medicines and medical devices. Two distinctions are worth carrying.

Medicines are authorised. A medicine placed on the UK market holds a marketing authorisation, and authorised medicines have public information about their approved uses. Botulinum toxin products are prescription only medicines, which is why they cannot be advertised to the public.

Devices are conformity assessed. Devices are placed on the market under conformity assessment procedures with a marking such as UKCA or CE. That process relates to the product meeting requirements for being placed on the market. It is not a regulator's endorsement of a cosmetic result, and it says nothing at all about the person using the device on you.

So the sentence it is fully approved means different things depending on which category the item is in, and often means less than the speaker intends. Ask which category, and by whom.

Clinical evidence claims

Clinically proven is not a regulated phrase and is used across a wide range of underlying evidence. The way to test it is to ask a single question: which study, and where can I read it.

What you are looking for is a traceable reference. A published paper in a journal, with authors and a date, that you can look up. Where a claim is significant to your decision, that reference is a reasonable thing to ask for, and advertisers should hold evidence for objective claims before making them, as set out in the advertising article.

Two cautions once you have a reference. Study populations may not resemble you, and a study of one product does not support claims about another. And a study funded by a manufacturer is not thereby worthless, but the funding is a fact you should know and it is usually declared in the paper.

Where a treatment has been examined by a national body such as NICE, that assessment is public and readable, and it is a more useful source than a marketing summary of it.

Five claim types, and how to test each
ClaimWhat it can meanThe question that tests it
ApprovedAuthorised as a medicine, or conformity assessed as a deviceWhich category, and by whom
Clinically provenAnything from a published trial to an in house testWhich study, and where can I read it
Medical gradeNo defined regulatory meaning hereWhat do you mean by that
PatentedA property right over an inventionWhat does the patent claim, and how is that relevant to results
Recommended by professionalsAnything or nothingWhich professionals, and on what basis
Award winningDepends entirely on the awardWhich award, given by whom, judged how

A framework written by this publication to organise the procedure. It is not a measurement, a guideline or a regulator's classification.

Vocabulary that means nothing in particular

Some terms carry no defined regulatory meaning in this context and should be treated as description rather than credential.

  • Medical grade. Not a defined regulatory category for cosmetic products. Ask what is meant.
  • Pharmaceutical grade. Similarly undefined in this usage.
  • Patented. A patent is a property right over an invention. It is not evidence that the invention works.
  • Award winning. Ask which award, given by whom, and on what basis.
  • Advanced or next generation. Marketing language, carrying no defined content.

None of these means a product is bad. They mean the words are not doing the work people assume, and that the actual question, which is what the product is and what evidence supports the claim, has not yet been answered.

Supply chain, briefly

For medicines, the supply route matters, and products obtained outside proper channels are a genuine concern that the MHRA takes seriously. You are entitled to ask that the product name and batch number are recorded in your notes, and to be shown the packaging.

For devices, the same request is reasonable. A clinic that records product and batch as routine practice is doing what a well run service does, and it is also creating the record you would need if anything went wrong. See records and photographs.

Reporting a problem with a product

The MHRA Yellow Card scheme receives reports about suspected side effects of medicines and about adverse incidents involving medical devices, and patients can report directly. It needs the product name and ideally the batch number, which is the second reason to have recorded them.

Reporting is one of the few things a single patient can do that contributes to detecting problems affecting other people. It takes a few minutes and requires no permission from anyone. What else to do at that point is in what to do when something goes wrong.

Common questions

What does CE or UKCA marking on a device mean?

It relates to the product having been through conformity assessment for being placed on the market. It is not a regulator's endorsement of a cosmetic result and says nothing about the qualifications of the person using the device on you.

How do I test a clinically proven claim?

Ask which study supports it and where you can read it. You are looking for a traceable published reference with authors and a date. Advertisers should hold documentary evidence for objective claims before making them.

Does medical grade mean anything?

It is not a defined regulatory category for cosmetic products. Treat it as description rather than credential, and ask what is actually meant by it.

Should a clinic tell me the product name and batch number?

Yes, and it is reasonable to ask that both are recorded in your notes and to see the packaging. You would need that information for a Yellow Card report or for any later complication.

How do I report a problem with a product or device?

Through the MHRA Yellow Card scheme, which takes reports directly from patients about medicines and about adverse incidents involving medical devices. Have the product name and batch number ready.

Sources and registers

Links to regulators, registers and published law. They are cited because they are public and checkable, not as endorsement of this publication. Open each one and read it yourself.

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