The Aesthetic Emergency Kit: What Can Practitioners Actually Hold?

If you work in aesthetics, you’ve probably been told:

“You need an emergency kit.”

That sounds straightforward.

Then you look at some of the medicines practitioners are commonly told to have available:

Hyaluronidase. Adrenaline. An adrenaline auto-injector. Chlorphenamine. Hydrocortisone.

And suddenly the question becomes much less straightforward:

If some of these are prescription-only medicines, can an aesthetic practitioner actually keep them in an emergency kit?

And if an emergency happens, can they use them?

These are important questions for all aesthetic practitioners — not just doctors and nurses.

The answer becomes much easier once one distinction is understood:

Holding a medicine and administering it in an emergency are not necessarily the same legal question.

That distinction sits at the centre of this guide.

First Things First: Can an Aesthetic Practitioner Have an Emergency Kit?

Yes — practitioners can and should have appropriate emergency arrangements for the treatments they provide. But an “emergency kit” is not itself a medicines-law category or exemption.

A practitioner can have appropriate emergency equipment and arrangements relevant to the treatments they provide.

Putting a prescription-only medicine into a bag labelled “Emergency Kit” does not automatically give every practitioner the right to purchase and hold that medicine as general clinic stock.

Instead, each medicine needs to be considered separately.

Ask:

• What exactly is the medicine?
• Is it prescription-only?
• How was it supplied?
• Is it general clinic stock or has it been supplied for a particular patient?
• Does my profession have a specific medicines exemption?
• Is there a specific emergency provision allowing it to be administered?

The principle is actually quite simple:

You need to know both why you are permitted to hold a medicine and why you are permitted to administer it.

Holding It and Using It Are Different Questions

Imagine there is a medicine in your emergency kit.

There are two separate questions.

Question 1: Am I allowed to obtain and hold it?

That’s about supply and stockholding.

Question 2: If somebody has an emergency, am I allowed to administer it?

That’s about administration.

A medicine can have a specific legal exemption allowing emergency administration without that automatically creating a general right for every practitioner or clinic to purchase quantities of it as stock.

Likewise, being trained to administer a medicine doesn’t automatically give somebody prescribing rights or a right to purchase POM stock.

Training, prescribing, supply, stockholding and emergency administration are related — but they are not the same thing.

So What Can Actually Be in an Aesthetic Emergency Kit?

There isn’t one universal list that applies to every aesthetic practitioner.

A kit may contain emergency equipment and non-POM products alongside medicines subject to additional legal controls.

When POMs are involved, the position can depend on:

• the exact medicine;
• how it is being supplied;
• whether it is general stock or patient-specific;
• the practitioner’s professional status;
• whether a profession-specific medicines exemption applies; and
• whether a specific emergency-administration provision applies.

So avoid two misleading extremes:

“Medics can keep POMs and non-medics can’t.”

That’s too simplistic.

And:

“If you’ve been trained to use it, you can keep it.”

That’s too simplistic too.

The better question is:

What medicine is it, who are you, and what lawful route allows you to obtain and hold it?

What About Hyaluronidase?

This is probably the best example of why practitioners become confused.

If you administer hyaluronic-acid dermal fillers, you will almost certainly have been taught about hyaluronidase and its role in managing certain filler complications.

Hyaluronidase is a prescription-only medicine (POM).

The Government’s original licensing consultation also describes hyaluronidase as a POM that is not licensed for dissolving dermal fillers but is used off-label for correcting problems with dermal filler injections. Read the Government consultation.

So practitioners quite reasonably ask:

“If I’m expected to be prepared for a filler complication, shouldn’t I have hyaluronidase available?”

Having an appropriate complication pathway is important.

But there’s a separate medicines question:

How will you lawfully access the hyaluronidase?

There is no general rule saying that because hyaluronidase may be required urgently, every aesthetic practitioner can simply purchase it as general emergency stock.

Completing complications training doesn’t itself create prescribing rights.

Having insurance doesn’t create prescribing rights.

And being told on a training course that you should keep hyaluronidase does not itself create a lawful supply route for a POM.

That does not mean:

“Aesthetic practitioners can’t have access to hyaluronidase.”

It means the appropriate lawful pathway needs to be established before it is needed.

Government Has Recognised the Problem

Practitioners aren’t imagining the apparent contradiction between being told to prepare for complications and the restrictions surrounding some medicines.

In its response to the consultation on licensing non-surgical cosmetic procedures in England, the Government recorded concerns about current legislation preventing nurse independent prescribers from holding stocks of prescription medicines.

Respondents raised concerns that this could impede timely access to medicines needed during an emergency or complication, specifically citing adrenaline for anaphylaxis and hyaluronidase for dermal-filler complications. Read the Government consultation response.

This is important because it demonstrates that the practical difficulty has been recognised at Government level.

There is a genuine tension between:

“Be prepared for complications.”

and:

“Make sure the medicines required are obtained and held through a lawful route.”

However, respondents raising the problem and Government recording it does not itself create a new stockholding exemption or change the law that applies today.

Adrenaline Is Different

This is where the distinction between holding and administering becomes particularly important.

Adrenaline is a POM.

However, the Human Medicines Regulations 2012 contain a specific exemption concerning certain medicines administered for the purpose of saving life in an emergency.

Regulation 238 and Schedule 19 include adrenaline 1:1000 up to 1mg for intramuscular use in anaphylaxis.

Schedule 19 also lists chlorphenamine injection and hydrocortisone injection, among other specified medicinal products.

That means there is a specific legal provision relating to emergency administration.

But here’s the crucial point:

The emergency exemption concerns administration. It should not be confused with a blanket right for every aesthetic practitioner to purchase POMs as general clinic stock.

So there are still two questions:

How was the adrenaline lawfully obtained and held?

and:

Can it be administered in the circumstances of the emergency?

Don’t merge the two.

What About an EpiPen or Jext?

This is another area where practitioners can receive overly simple advice:

“Just keep an EpiPen in your kit.”

Adrenaline auto-injectors are prescription medicines.

There are specific legal arrangements allowing certain organisations, such as schools, to obtain spare adrenaline auto-injectors.

The relevant lesson here is not the school scheme itself. It is the distinction:

The law can treat obtaining emergency stock and administering a medicine during an emergency as separate matters.

So an aesthetic practitioner shouldn’t assume:

“Anyone can buy an EpiPen as clinic stock because adrenaline can be administered in an emergency.”

The second statement does not automatically establish the first.

The lawful procurement route still needs to be established.

What About Chlorphenamine and Hydrocortisone?

Chlorphenamine injection and hydrocortisone injection are listed within Schedule 19 of the Human Medicines Regulations.

Again, however, this doesn’t mean:

“Every antihistamine and every steroid can be freely purchased for an aesthetic emergency kit.”

The exact medicine and formulation matter.

And once again:

Emergency administration and obtaining stock are separate issues.

There is also an important clinical distinction. Current Resuscitation Council UK guidance identifies intramuscular adrenaline as first-line treatment for anaphylaxis. The appearance of chlorphenamine or hydrocortisone in Schedule 19 is a medicines-law point; it does not make them equivalent to adrenaline in current anaphylaxis treatment guidance.

What About Saline?

This is another area where phrases such as:

“It’s only saline.”

can create confusion.

Different sodium chloride products, presentations and uses exist.

The legal position therefore shouldn’t be decided simply from the everyday word “saline”.

Check the exact product, its classification, intended use and the supply route that applies to the practitioner.

The same principle should be applied to other medicines or products being placed into an aesthetic emergency or complications kit.

What About Antibiotics?

Antibiotics shouldn’t simply become another product put into an emergency bag “just in case.”

If a patient develops symptoms suggesting infection, they may require appropriate clinical assessment and, where indicated, prescribing.

That’s different from the Schedule 19 provisions relating to specified medicines administered for the purpose of saving life in an emergency.

Not every medicine that might be useful following an aesthetic treatment is an “emergency medicine” in the legal sense.

A Simple Guide to Commonly Discussed Emergency Medicines

Hyaluronidase

It is a POM.

There is no blanket aesthetic emergency-kit exemption allowing every practitioner to purchase it as general stock.

An appropriate lawful supply route needs to be established.

It is not listed within Schedule 19 simply because it may be required urgently for a filler complication.

Adrenaline 1:1000

Adrenaline is a POM.

Specified adrenaline is included within Schedule 19 for emergency administration in the circumstances set out in the legislation.

However, the emergency-administration provision should not automatically be interpreted as a general stock-purchasing right.

Adrenaline Auto-Injectors

These are medicinal products and their procurement or stockholding needs to be considered separately from emergency administration.

Don’t assume that because an auto-injector may be used to save a life, every aesthetic clinic automatically has a right to purchase one as general stock.

Chlorphenamine Injection

Chlorphenamine injection appears within Schedule 19.

Procurement and stockholding remain separate questions from emergency administration.

Hydrocortisone Injection

Hydrocortisone injection appears within Schedule 19.

Again, the emergency-administration provision should not be confused with a general stock-purchasing exemption.

Saline

The exact product, formulation, intended purpose and supply route matter.

Don’t determine its legal status simply from the word “saline”.

Antibiotics and Other POMs

There is no general aesthetic emergency-kit exemption allowing practitioners to hold any POM that might conceivably be useful following treatment.

The appropriate clinical and medicines-supply pathway needs to be established.

What If You’re a Non-Medical Aesthetic Practitioner?

This article should not be interpreted as saying non-medical practitioners shouldn’t have emergency arrangements.

Quite the opposite.

If you provide aesthetic procedures, your emergency arrangements should reflect the treatments you perform and the potential complications associated with them.

A responsible non-medical practitioner should understand:

• what can go wrong;
• how to recognise an emergency;
• what they are trained and competent to do;
• what medicines they can lawfully access;
• when another healthcare professional needs to become involved; and
• when emergency or specialist care is required.

What training doesn’t do is automatically change medicines law.

A certificate showing that you’ve been trained to administer a particular medicine is evidence of training.

It isn’t, by itself, a prescription or a statutory right to purchase POM stock.

That distinction should be explained clearly — not used to frighten practitioners.

What If You’re a Healthcare Professional?

Being a registered healthcare professional doesn’t mean every POM automatically becomes available to you as clinic stock either.

Different professions can have different statutory medicines exemptions. MHRA guidance explains profession-specific sale, supply and administration exemptions.

Professional registration, prescribing status, scope of practice, the particular medicine and the intended supply route can all matter.

That’s why:

“I’m a medic.”

isn’t enough information to answer the stockholding question.

And:

“I’m a non-medic.”

isn’t enough information either.

Start with the medicine and supply route, then establish what applies to the individual practitioner.

What If You Work With a Prescriber?

Another common assumption is:

“It’s fine — my prescriber supplies my emergency kit.”

That needs closer examination.

A prescriber prescribing a medicine for an identified patient following appropriate assessment is not necessarily the same thing as supplying a clinic with a pool of POMs intended for unidentified future patients.

For NMC independent nurse and midwife prescribers, the rules are particularly important.

Since 1 June 2025, the NMC requires a face-to-face consultation and documented appropriate clinical assessment of the intended recipient before an independent nurse or midwife prescriber prescribes medicinal products used for elective non-surgical cosmetic procedures. Read the current NMC guidance.

The NMC also states that where administration is delegated, the prescriber remains responsible for overall oversight and care of the individual, including outcomes and adverse incidents or complications.

So:

“My prescriber prescribed my emergency kit” should not be used as a catch-all explanation for general POM stock.

The actual prescribing and supply route needs to be appropriate.

Patient-Specific Medicine Is Not the Same as General Stock

This distinction is easy to lose in everyday practice.

A medicine prescribed and dispensed for a named patient has been supplied for that patient.

General stock is different.

It is medicine held in anticipation that an unidentified future patient might need it.

Those aren’t interchangeable concepts.

So if a medicine has been supplied for Patient A, don’t automatically assume that it has become the clinic’s general emergency stock for Patients B, C and D.

Specific emergency-administration provisions may apply to certain medicines in particular circumstances, but those provisions should be considered separately.

What Happens If There Is an Actual Emergency?

This part is much simpler.

If a serious or life-threatening emergency occurs:

• Deal with the emergency.
• Stop the elective procedure.
• Follow your current emergency training and established emergency protocol.
• Call 999 promptly where emergency medical assistance is required.
• Use equipment and medicines in accordance with your training, competence and the applicable legal framework.

For suspected anaphylaxis, current Resuscitation Council UK guidance identifies intramuscular adrenaline as the first-line treatment.

Most importantly:

Do not delay necessary emergency medical care while waiting for a prescriber to answer the phone.

A prescriber may form part of the patient’s wider clinical and complication pathway.

They are not a substitute for emergency services when somebody requires emergency medical assistance.

What If It Isn’t a Life-Threatening Emergency?

Not every aesthetic complication requires 999.

Depending on the circumstances, the appropriate response may involve:

• following the established complication protocol;
• involving the prescriber;
• arranging clinical assessment;
• obtaining urgent specialist assessment; or
• referring the patient to another appropriate healthcare service.

That pathway should already exist.

The emergency or complication itself should not be the moment the practitioner discovers:

“I can’t access the medicine.”

or:

“I thought my prescriber dealt with this.”

or:

“I don’t know whether I’m allowed to use what’s in the kit.”

Emergency and complication planning happens before treatment, not during the emergency.

Don’t Confuse These Four Statements

“I’ve been trained to use it.”

That doesn’t automatically mean you can purchase it as POM stock.

“My prescriber gave it to me.”

That doesn’t automatically establish that it was lawfully supplied as general clinic stock.

“It can be administered in an emergency.”

That doesn’t automatically establish a general right to purchase and hold it.

“It’s a POM.”

That doesn’t necessarily mean nobody other than a prescriber can ever administer it. Specific statutory emergency provisions exist for certain medicines.

Understanding those distinctions removes much of the confusion around aesthetic emergency kits.

Why This Matters

Government consultation work on future regulation of non-surgical cosmetic procedures has already recognised concerns around timely access to medicines used for emergencies and complications.

That is important.

It shows that this isn’t simply practitioners “getting it wrong”.

There is a genuine issue around balancing appropriate emergency preparedness with lawful medicines supply and governance.

Practitioners should therefore be cautious about absolute statements circulating online such as:

“Nobody can have that.”

or:

“Everyone must keep that.”

The answer can depend on the medicine, practitioner and supply route.

The Bottom Line

Aesthetic practitioners can have emergency kits.

They should be prepared for emergencies and complications relevant to the treatments they provide.

But:

“Emergency kit” is not a blanket medicines-law exemption.

Some products can be held without the restrictions applicable to POMs.

Some POMs require an appropriate lawful prescribing or supply route.

Some healthcare professions have specific statutory medicines exemptions.

And certain medicines have specific legal provisions allowing administration for the purpose of saving life in an emergency.

The most important distinction is:

HOLDING IT AND USING IT ARE NOT NECESSARILY THE SAME LEGAL QUESTION.

Being permitted to administer a medicine in a defined emergency does not automatically give every practitioner permission to purchase that medicine as general clinic stock.

And being trained to use a POM doesn’t automatically create a right to obtain it as stock.

So:

Have the emergency kit.

Be prepared.

Know what’s inside it.

Know how it was supplied.

Know what you’re permitted to do with it.

And establish those arrangements before the emergency happens.

Continue Reading

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Aesthetics Training & Qualifications: What Does Your Certificate Actually Mean?

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POM Ordering & Practitioner Verification

Understand why pharmacies ask for particular information and how POM supply differs from ordinary aesthetic products.

Aesthetic Prescription Errors: 9 Common Mistakes

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Injectable Aftercare

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Who Can Prescribe Botulinum Toxin in the UK?

A dedicated guide to prescribing responsibilities for botulinum toxin.

FAQ: Aesthetic Emergency Kits & Medicines

Can a non-medical aesthetic practitioner have an emergency kit?

Yes — practitioners can and should have appropriate emergency arrangements for the treatments they provide. But the lawful position of any medicine inside the kit depends on the medicine, the route by which it was supplied, the practitioner’s status and any relevant emergency-administration provision. Training alone does not create a right to purchase POM stock.

Can aesthetic practitioners keep hyaluronidase?

Hyaluronidase is a prescription-only medicine, so there is no blanket rule allowing every aesthetic practitioner to purchase it as general clinic stock simply because it may be needed urgently. The lawful supply route needs to be established before it is needed. Government consultation material also describes its use for dissolving dermal filler as off-label.

Can a non-medical practitioner administer adrenaline in an emergency?

Regulation 238 and Schedule 19 of the Human Medicines Regulations contain an emergency-administration exemption for specified medicines, including adrenaline 1:1000 up to 1mg for intramuscular use in anaphylaxis. That administration provision should be considered separately from how the adrenaline was lawfully obtained and held.

Can an aesthetic clinic keep an EpiPen or Jext?

Do not assume that emergency use creates a general stockholding right. Adrenaline auto-injectors are prescription medicines, so the procurement and stockholding route needs to be considered separately from emergency administration.

Can a prescriber prescribe an emergency kit?

A prescriber can prescribe medicines where the relevant legal and professional requirements are met, but a patient-specific prescription for an identified person is not automatically the same thing as supplying a clinic with general stock for unidentified future patients. The actual prescribing and supply route must be appropriate.

Is patient-specific medication the same as clinic stock?

No. Medicine prescribed and dispensed for a named patient has been supplied for that patient. General clinic stock is medicine held for possible use in an unidentified future patient. Those concepts should not be treated as interchangeable.

What should be in an aesthetic emergency kit?

There is no single universal medicines list for every practitioner. The contents should reflect the treatments provided, potential emergencies, the practitioner’s competence, the exact products involved and the lawful route by which any medicines are obtained and held. Emergency equipment and planning are important, but an “emergency kit” does not create a general medicines-law exemption.

Reviewed: September 2026.

This article provides general educational information for aesthetic practitioners in England. It is not individual legal or clinical advice. Medicines rules can depend on the exact product, formulation, route, professional status, circumstances of supply and intended use. Practitioners should check current legislation, relevant professional standards and pharmacy advice for their own circumstances.

Key Sources

• Human Medicines Regulations 2012 — Regulation 238 and Schedule 19
• Nursing and Midwifery Council — Useful information for prescribers
• Department of Health and Social Care — consultation response
• MHRA — rules for the sale, supply and administration of medicines for specific healthcare professionals
• Resuscitation Council UK — Emergency treatment of anaphylaxis