Practitioners & Therapists

Practitioners & Therapists

Have you ever considered supplementing your business by using tailor-made products during your treatments, and selling these personalised products to your clients? Are you considering creating your own beauty brand alongside your complementary therapy business?

As a registered practitioner, there are certain regulations that are relevant to you:

Part 3, manufacturing of medicinal products: requirement for licence, paragraph (6) of the Human Medicines Regulation 2012:


(6) This paragraph applies where a herbal medicinal product is manufactured or assembled by a person (“A”) if—


(a) the manufacture or assembly takes place on premises occupied by A and from which A can exclude the public;


(b) the product is for administration to a person (“B”) and A has been requested by or on behalf of B, and in B’s presence, to use A’s judgment as to the treatment required;


(c) the product does not contain a substance specified in Part 1 of Schedule 20;


(d) the product does not contain a substance listed in Part 2 of that Schedule, unless the product is sold or supplied—

(i) in or from containers or packages labelled to show a dose not exceeding the maximum dose or maximum daily dose specified in column 2 of that Part, or

(ii) in the case of a product for external use only, with a percentage of the substance in the product that does not exceed the percentage specified in column 3 of that Part; and


(e) the condition in paragraph (9) is met.




(9) This condition is that the medicinal product is not manufactured or, as the case may be, assembled—


(a) on a large scale; or


(b) by an industrial process.



This type of exemption from other EU regulations was previously referred to as the "herbalists' exemption" under Section 12 of the Medicines Act 1968.


It essentially means that as a registered practitioner you are allowed to make tailored products to use during therapies or to give to clients, without having to obtain the same licenses as if you were selling them to the public outside of your practice.


This gives you the opportunity to supplement your business, and give yourself an advantage over your competitors. It's also a great way of laying the foundations of a new business venture. Your industry knowledge will give you an edge over other brands on the market, and you'll be able to develop a product range within the scope of your complementary therapies without needing to have everything tested and licensed beforehand.


If you're new to the concept of making your own products, take a look at our advice for beginners and tips for Home Crafters.


If you're wanting to sell your products to the public (i.e. not including your clients), then you should familiarise yourself with the regulations surrounding EU cosmetics as a Business Owner.